FFIEC031_FFIEC041_FFIEC051_20180414_omb

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Consolidated Reports of Condition
and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036).
These data are required of state member banks and are filed on a quarterly basis. The revisions
to the Call Reports that are the subject of this request have been approved by the FFIEC. The
Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency
(OCC) have also submitted a similar request for OMB review to request this information from
banks under their supervision.
The Board requires information collected on the Call Reports to fulfill its statutory
obligation to supervise state member banks. State member banks are required to file both
detailed schedules of assets, liabilities, and capital accounts in the form of a condition report and
summary statement as well as detailed schedules of operating income and expense, sources and
disposition of income, and changes in equity capital.
The Board, the FDIC, and the OCC (the agencies) propose to revise the Call Reports to
be submitted on or after July 1, 2018, beginning with the reports reflecting the June 30, 2018,
report date, by deleting or consolidating of a number of items and adding a new or raising certain
existing reporting thresholds. The current annual burden for the Call Reports is estimated to be
169,861 hours and the proposed revisions are estimated to decrease the annual burden by 6,290
hours.
Background and Justification
Banks that are members of the Federal Reserve System, pursuant to section 9(6) of the
Federal Reserve Act (12 U.S.C. 324), are required by law to file reports of condition with the
Board. The Board, acting in concert with the other federal banking supervisory agencies since
1979 through the FFIEC, requires banks to submit on the quarterly Call Reports such financial
data as are needed by the Federal Reserve System to supervise and regulate banks through
monitoring of their financial condition, ensuring the continued safety of the public’s monies and
the overall soundness of the nation’s financial structure, and to contribute information needed for
background for the proper discharge of the Federal Reserve’s monetary policy responsibilities.
The data, which generally is made publicly available by the agencies, is used not only by the
federal government, but also by state and local governments, the banking industry, securities
analysts, and the academic community.

Description of Information Collection
The Call Reports, which consist of the Reports of Condition and Income, collect basic
financial data from commercial banks in the form of a balance sheet, income statement, and
supporting schedules. The Report of Condition contains supporting schedules that provide detail
on assets, liabilities, and capital accounts. The Report of Income contains supporting schedules
that provide detail on income and expenses.
Within the Call Report information collection system as a whole, there are three reporting
forms that apply to different categories of banks: (1) all banks that have domestic and foreign
offices (FFIEC 031), (2) banks with domestic offices only (FFIEC 041), and (3) banks with
domestic offices only and total assets less than $1 billion (FFIEC 051).1
There is no other series of reporting forms that collect from all commercial and savings
banks this information. Although there are other information collections that are similar to
certain items on the Call Reports, the information they collect would be of limited value as a
replacement for the Call Reports. For example, the Board collects various data in connection
with its measurement of monetary aggregates, bank credit, and flow of funds. Reporting banks
supply the Board with detailed information relating to balance sheet accounts such as balances
due from depository institutions, loans, and deposit liabilities. These collections of information,
however, are frequently obtained on a sample basis rather than from all insured banks.
Moreover, these reports are often prepared as of dates other than the last business day of each
quarter, which would seriously limit their comparability. Additionally, institutions below a
certain size are exempt entirely from some Board reporting requirements.
The Board also collects financial data from bank holding companies on a regular basis.
Such data frequently are presented for the holding company on a consolidated basis, including its
banking and nonbanking subsidiaries, and on a parent company only basis. Data collected from
bank holding companies on a consolidated basis reflect aggregate amounts for all subsidiaries
within the organization, including banking and nonbanking subsidiaries, so that the actual dollar
amounts applicable to any banking subsidiary would not be determinable from the holding
company reporting information. Hence, these reporting forms are not a viable replacement for
even a significant portion of the Call Reports since the Board, in its role as supervisor of insured
state member banks, would lack the data necessary to assess the financial condition of individual
banks to determine whether there had been any deterioration in their condition.
Banks are required to transmit their Call Report data electronically. Banks do not have to
submit hard copy Call Reports to any federal bank supervisory agency unless specifically
requested to do so.

1

Prior to March 2001, there were four categories of banks and four reporting forms. The FFIEC 031 was filed by
banks with domestic and foreign offices and the FFIEC 032, FFIEC 033, and FFIEC 034 were filed by banks with
domestic offices only according to the asset size of the bank. Prior to March 2017, there were two categories of
banks and two reporting forms. The FFIEC 031 was filed by banks with domestic and foreign offices and the (2) the
FFIEC 041 was filed by banks with domestic offices only.

2

Proposed Revisions
As part of an initiative launched by the FFIEC in December 2014 to identify potential
opportunities to reduce burden associated with Call Report requirements for community banks,
the FFIEC and the agencies have taken several actions, including: (1) adopting in mid-2016 a
number of burden-reducing revisions to the Call Report that became effective in September 2016
and March 2017; (2) communicating with respondent banks to obtain a better understanding of
significant sources of reporting burden in their Call Report preparation processes; (3) creating a
new streamlined FFIEC 051 Call Report for eligible small banks2 that took effect as of the March
31, 2017, report date; and (4) publishing for comment in June 2017 additional proposed burdenreducing Call Report revisions, as well as other proposed Call Report revisions that address the
definition of “past due” for regulatory reporting purposes and changes in the accounting for
equity investments, all of which have a proposed March 31, 2018, effective date.3
As another key part of the FFIEC’s Call Report burden-reduction initiative for
community banks, in 2015 the agencies accelerated the start of the next statutorily mandated
review of the existing Call Report data items (Full Review),4 which otherwise would not have
commenced until 2017. After completing this review, the agencies are required to “reduce or
eliminate any requirement to file information or schedules . . . (other than information or
schedules that are otherwise required by law)” if the agencies determine that “the continued
collection of such information or schedules is no longer necessary or appropriate.”5 To provide a
foundation for the Full Review, users of Call Report data items, who are internal staff at the
FFIEC member entities, participated in a series of nine surveys conducted over a 19-month
period that began in mid-July 2015 and ended in mid-February 2017. As part of these surveys,
users were asked to fully explain the need for each Call Report data item they deem essential,
how the data item is used, the frequency with which it is needed, and the population of
institutions from which it is needed. Call Report schedules were placed into nine groups and
prioritized for review, generally based on the level of burden cited by banking industry
representatives. Based on the results of the user surveys and consistent with the statutory
requirements governing the Full Review, the agencies have been identifying data items to be
considered for removal, less frequent collection, and new or revised reporting thresholds to
reduce burden.
Based on the results of the third and final portion of the user surveys and other
information, the agencies are proposing various burden-reducing changes in this proposal. The
schedules reviewed in the final portion of the user surveys primarily include schedules that
collect data on complex or specialized activities. A summary of the FFIEC member entities’
uses of the data items retained in the Call Report schedules covered by this portion of the user

2

Generally, institutions with domestic offices only and total assets less than $1 billion.
See 80 FR 56539 (September 18, 2015), 81 FR 45357 (July 13, 2016), 81 FR 54190 (August 15, 2016) (referred to
hereafter as the “August 2016 Call Report proposal”), 82 FR 2444 (January 9, 2017), and 82 FR 29147 (June 27,
2017) (referred to hereafter as the “June 2017 Call Report proposal”) for further information on the actions taken
under this initiative.
4
This review is mandated by section 604 of the Financial Services Regulatory Relief Act of 2006 (12 U.S.C.
1817(a)(11)).
5
See 12 U.S.C. 1817(a)(11)(B).
3

3

surveys is included in Appendix A.6 Several of these schedules were not included in the new
FFIEC 051 when it was created. Therefore, revisions proposed in this notice more significantly
affect schedules and data items in the FFIEC 031 and FFIEC 041.
In addition, as a framework for the actions it is undertaking, the FFIEC developed a set of
guiding principles for use in evaluating potential additions and deletions of Call Report data
items and other revisions to the Call Report. In general, data items collected in the Call Report
must meet three guiding principles: (1) the data items serve a long-term regulatory or public
policy purpose by assisting the FFIEC member entities in fulfilling their missions of ensuring the
safety and soundness of financial institutions and the financial system and the protection of
consumer financial rights, as well as agency-specific missions affecting federally and statechartered institutions; (2) the data items to be collected maximize practical utility and minimize,
to the extent practicable and appropriate, burden on financial institutions; and (3) equivalent data
items are not readily available through other means.
General Discussion of Proposed Call Report Revisions
As discussed above, the Call Report schedules have been reviewed as part of the Full
Review, conducted through a series of nine user surveys. The results of the final portion of the
surveys were evaluated in the development of this proposal. In addition, the results of certain
surveys were re-evaluated and further burden-reducing changes were incorporated into this
proposal. In developing this proposal, the agencies were cognizant of the comments and
feedback received from the industry, over the course of this FFIEC initiative, requesting that the
agencies provide relief from the burden of preparing Call Reports.
The schedules reviewed in the portion of the user surveys evaluated in the development
of this proposal include:
 Schedule RI-A – Changes in Bank Equity Capital
 Schedule RI-C – Disaggregated Data on the Allowance for Loan and Lease Losses
(FFIEC 031 and FFIEC 041 only)
 Schedule RC-A – Cash and Balances Due from Depository Institutions
 Schedule RC-F – Other Assets
 Schedule RC-G – Other Liabilities
 Schedule RC-H – Selected Balance Sheet Items for Domestic Offices (FFIEC 031 only)
 Schedule RC-I – Assets and Liabilities of IBFs (FFIEC 031 only)
 Schedule RC-P – 1-4 Family Residential Mortgage Banking Activities (in Domestic
Offices) (FFIEC 031 and FFIEC 041 only)
 Schedule RC-Q – Assets and Liabilities Measured at Fair Value on a Recurring Basis
(FFIEC 031 and FFIEC 041 only)
 Schedule RC-S – Servicing, Securitization, and Asset Sale Activities (FFIEC 031 and
FFIEC 041 only)
 Schedule RC-T – Fiduciary and Related Services
6

A summary of the FFIEC member entities’ uses of the data items retained in the Call Report schedules covered by
the first and second portions of the agencies’ user surveys are included in Appendix A of the agencies’ Federal
Register notices published on January 9, 2017 (82 FR 2444) and June 27, 2017 (82 FR 29147), respectively.

4



Schedule RC-V – Variable Interest Entities (FFIEC 031 and FFIEC 041 only)





The schedules re-evaluated in the development of this proposal include:
Schedule RC-B – Securities
Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets
Schedule SU – Supplemental Information (FFIEC 051 only)

Table 1 summarizes the changes already finalized and implemented as part of the
FFIEC’s community bank Call Report burden-reduction initiative.
Table 1 – Data Items Revised as of March 31, 2017
Finalized Call Report Revisions
Items Removed, Net*
Change in Item Frequency to Semiannual
Change in Item Frequency to Annual
Items with a New or Increased Reporting
Threshold

051
967
96
10

041
60

031
68

7

13

* “Items Removed, Net” reflects the effects of consolidating existing items, adding control
totals, and, for the FFIEC 051, relocating individual items from other schedules to Schedule SU,
some of which were consolidated in Schedule SU. In addition, included in this number for the
FFIEC 051, approximately 300 items were items that institutions with less than $1 billion in total
assets were exempt from reporting due to existing reporting thresholds in the FFIEC 041.
Table 2 summarizes the proposed burden-reducing revisions to data items included in the
June 2017 Call Report proposal that would take effect March 31, 2018.
Table 2 – Proposed Data Revisions in June 2017
Proposed Call Report Revisions
Items Proposed to be Removed, Net*
Proposed Change in Item Frequency to
Semiannual
Proposed Change in Item Frequency to Annual
Items with a Proposed New or Increased
Reporting Threshold

051
54

041
106

031
86

17
26

31
3

31
3

26

106

178

“Items Proposed to be Removed, Net” reflects the effects of consolidating existing items and
relocating individual items to other schedules.
*

Table 3 summarizes the additional proposed burden-reducing revisions to data items
included in this notice. Detail for each affected data item is shown in Appendix B (FFIEC 051),
Appendix C (FFIEC 041), and Appendix D (FFIEC 031).

5

Table 3 – Proposed Data Revisions in this Notice
Proposed Call Report Revisions
Items Proposed to be Removed, Net*
Items with a Proposed New or Increased
Reporting Threshold

051
7

041
184

031
134

29

181

213

* “Items Proposed to be Removed, Net” reflects the effects of consolidating existing items and
relocating individual items to other schedules.
The Call Report revisions that are the subject of this proposal would take effect June 30,
2018.
Detail of Specific Proposed Call Report Revisions
A. Revisions to the FFIEC 051
Schedule RC-A
The agencies propose to remove Schedule RC-A, Cash and Balances Due from
Depository Institutions, in its entirety from the FFIEC 051. This schedule is currently completed
by institutions with $300 million or more in total assets. The agencies no longer need the current
level of detail provided by the existing items in Schedule RC-A from the smaller institutions
eligible to file this version of the Call Report who are required to complete this schedule, as
sufficient information on cash and due from balances is provided for these institutions in
Schedule RC, items 1.a and 1.b.
Schedule RC-B
With respect to Schedule RC-B of the FFIEC 051, the agencies propose to consolidate
the reporting of an institution’s holdings of those residential mortgage pass-through securities
that are currently reported in items 4.a.(1) for those guaranteed by the Government National
Mortgage Association (GNMA) and 4.a.(2) for those issued by the Federal National Mortgage
Association (FNMA) and the Federal Home Loan Mortgage Corporation (FHLMC) into a single
item 4.a.(1). Existing item 4.a.(3) for other residential mortgage pass-through securities would
be renumbered as item 4.a.(2). The agencies no longer need the current level of detail for these
holdings from the smaller institutions eligible to file this version of the Call Report.
Schedule RC-F
With respect to Schedule RC-F of the FFIEC 051, the agencies propose to consolidate the
reporting of an institution’s interest-only strips receivable, which are currently reported in items
3.a for those on mortgage loans and 3.b for those on other financial assets, into a single item 3.
The agencies no longer need the current level of detail for these holdings in the Call Report.
In addition, the agencies propose to remove the preprinted caption for retained interests in

6

accrued interest receivable related to securitized credit cards (item 6.d) as few institutions report
having this component of other assets in an amount in excess of the existing reporting threshold
for disclosing this component.7 Items 6.e through 6.k would be renumbered as items 6.d through
6.j.
Schedule RC-T
With respect to Schedule RC-T of the FFIEC 051, the agencies propose to increase the
reporting threshold for reporting the components of fiduciary and related services income. For
institutions with total fiduciary assets greater than $100 million but less than or equal to $250
million that do not meet the fiduciary income test for quarterly reporting,8 the agencies propose
to no longer require the reporting of items 14 through 26. There would be no change to the
reporting requirements applicable to items 14 through 26 for all other institutions. The agencies
no longer need the current level of detail on fiduciary and related services income from
institutions with less than $250 million in total fiduciary assets that do not meet the fiduciary
income test.
In addition, the agencies propose to add a reporting threshold for reporting the number
and market value of collective investment funds and common trust funds by type of fund in
Memorandum items 3.a through 3.g. For institutions at which these funds have a total market
value of less than $1 billion (as of the preceding December 31), the agencies propose to no
longer require the reporting of Memorandum items 3.a through 3.g. Such institutions would
report only the total number and market value of their collective investment funds and common
trust funds in Memorandum item 3.h. Institutions at which the total market value of their
collective investment funds and common trust funds is $1 billion or more would continue to
report Memorandum items 3.a through 3.h. The agencies no longer need the current level of
detail on collective investment funds and common trust funds in the Call Report from institutions
at which the total market value of these funds is less than $1 billion.
Schedule SU
With respect to Schedule SU of the FFIEC 051, the agencies propose to remove item 8.e
on the amount of outstanding credit card fees and finance charges included in credit card
receivables sold and securitized with servicing retained or with recourse or other seller-provided
credit enhancements, which is currently applicable to eligible small institutions that specialize in
credit card lending. The agencies no longer need this information from these smaller credit card
lending institutions.

7

If this preprinted caption were removed and an institution has retained interests in accrued interest receivable
related to securitized credit cards in an amount in excess of the reporting threshold, the institution would itemize and
describe this component in one of the subitems of item 6 without a preprinted caption.
8
An institution does not meet the fiduciary income test if its gross fiduciary and related services income was less
than or equal to 10 percent of revenue (net interest income plus noninterest income) for the preceding calendar year.

7

B. Revisions to the FFIEC 041
Schedule RC-A
With respect to Schedule RC-A of the FFIEC 041, the agencies propose to consolidate
the reporting of an institution’s balances due from depository institutions in the United States,
which are currently reported in items 2.a for balances due from U.S. branches and agencies of
foreign banks and 2.b for balances due from other commercial banks and other depository
institutions in the United States, into a single item 2. In addition, the agencies propose to
consolidate the reporting of an institution’s balances due from banks in foreign countries and
foreign central banks, which are currently reported in items 3.a for balances due from foreign
branches of other U.S. banks and 3.b for balances due from banks in foreign countries and
foreign central banks, into a single item 3. The agencies no longer need the current level of
detail for these balances in the Call Report.
Schedule RC-F
With respect to Schedule RC-F of the FFIEC 041, the agencies propose to consolidate the
reporting of an institution’s interest-only strips receivable, which are currently reported in items
3.a for those on mortgage loans and 3.b for those on other financial assets, into a single item 3.
The agencies no longer need the current level of detail for these holdings in the Call Report.
In addition, the agencies propose to remove the preprinted caption for retained interests in
accrued interest receivable related to securitized credit cards (item 6.d) as few institutions report
having this component of other assets in an amount in excess of the existing reporting threshold
for disclosing this component.9 Items 6.e through 6.k would be renumbered as items 6.d through
6.j.
Schedule RC-N
With respect to Schedule RC-N of the FFIEC 041, the agencies propose to remove the
data items for reporting the past due and nonaccrual status of the fair value and unpaid principal
balance of held-for-investment loans measured at fair value, which are currently reported in
Memorandum items 5.b.(1) and 5.b.(2), columns A through C. The agencies no longer need this
current level of detail in the Call Report. The agencies would renumber Memorandum item 5.a,
“Loans and leases held for sale,” as Memorandum item 5 for columns A through C.
Schedule RC-P
With respect to Schedule RC-P of the FFIEC 041, the agencies propose to modify the
reporting criteria for this schedule by removing the current $1 billion asset-size threshold and
applying only the existing activity-based threshold to all institutions, regardless of size. As
proposed, Schedule RC-P would be completed by institutions where any of the following
9

If this preprinted caption were removed and an institution has retained interests in accrued interest receivable
related to securitized credit cards in an amount in excess of the reporting threshold, the institution would itemize and
describe this component in one of the subitems of item 6 without a preprinted caption.

8

residential mortgage banking activities exceeds $10 million for two consecutive quarters:
 Closed-end and open-end first lien and junior lien 1-4 family residential mortgage loan
originations and purchases for resale from all sources during a calendar quarter; or
 Closed-end and open-end first lien and junior lien 1-4 family residential mortgage loan
sales during a calendar quarter; or
 Closed-end and open-end first lien and junior lien 1-4 family residential mortgage loans
held for sale or trading at calendar quarter-end.
The agencies believe an activity-based threshold alone is more appropriate than an asset-size
threshold for determining which institutions should file this schedule.
The agencies also propose to consolidate the 1-4 family residential mortgage banking
activity detail collected in this schedule for closed-end loans and commitments under open-end
loans for retail originations (item 1), wholesale originations and purchases (item 2), mortgage
loans sold (item 3), mortgage loans held for sale or trading (item 4), and repurchases and
indemnifications of mortgage loans (item 6). Specifically, items 1.a, 1.b, and 1.c.(1) would be
combined into new item 1; items 2.a, 2.b, and 2.c.(1) would be combined into new item 2; items
3.a, 3.b, and 3.c.(1) would be combined into new item 3; items 4.a, 4.b, and 4.c.(1) would be
combined into new item 4; and items 6.a, 6.b, and 6.c.(1) would be combined into new item 6.
The agencies also propose to consolidate noninterest income from the sale, securitization, and
servicing of closed-end and open-end 1-4 family residential mortgage loans currently reported in
items 5.a and 5.b into a new item 5. In addition, the agencies propose to remove detail on the
principal amount funded for open-end loans extended under lines of credit for each of the above
listed categories currently reported in items 1.c.(2), 2.c.(2), 3.c.(2), 4.c.(2), and 6.c.(2). The
agencies are proposing these changes because they no longer need the current level of detail on
1-4 family residential mortgage banking activities in the Call Report.
Schedule RC-Q
With respect to Schedule RC-Q of the FFIEC 041, the agencies propose to modify the
reporting criteria for this schedule by applying only an activity threshold and not an asset-size
threshold, which currently is $500 million. As proposed, Schedule RC-Q would be completed
only by institutions that (1) have elected to report financial instruments or servicing assets and
liabilities at fair value under a fair value option with changes in fair value recognized in earnings,
or (2) are required to complete Schedule RC-D, Trading Assets and Liabilities. Institutions that
do not meet either of these criteria would no longer need to complete this schedule, regardless of
asset size. The agencies believe the activity thresholds are more appropriate than the existing
simple asset-size threshold for determining which institutions must complete this schedule.
For loans held for investment and held for sale measured at fair value under a fair value
option, the agencies also propose to consolidate the detail on the fair value and the unpaid
principal balance of such loans currently collected in Memorandum items 3 and 4 of this
schedule. For fair value option loans secured by 1-4 family residential properties, detail on
revolving, open-end loans secured by 1-4 family residential properties and extended under lines
of credit; closed-end loans secured by first liens on 1-4 family residential properties; and closedend loans secured by junior liens on 1-4 family residential properties would be consolidated into
a single category. For fair value option loans secured by real estate other than 1-4 family

9

residential properties, detail on construction, land development, and other land loans; loans
secured by farmland; loans secured by multifamily (5 or more) residential properties; and loans
secured by nonfarm nonresidential properties also would be consolidated into a single category.
For fair value option consumer loans, detail on credit cards, other revolving credit plans,
automobile loans, and other consumer loans would be consolidated into a single category.
Specifically, existing Memorandum items 3.a.(3)(a), 3.a.(3)(b)(1), and 3.a.(3)(b)(2) would be
consolidated into new Memorandum item 3.a.(1) for the fair value of loans secured by 1-4 family
residential properties measured at fair value, while existing Memorandum items 3.a.(1), 3.a.(2),
3.a.(4), and 3.a.(5) would be consolidated into new Memorandum item 3.a.(2) for the fair value
of all other loans secured by real estate measured at fair value. Existing Memorandum items
3.c.(1) through 3.c.(4) would be consolidated into new Memorandum item 3.c for the fair value
of all consumer loans measured at fair value. Similarly, existing Memorandum items 4.a.(3)(a),
4.a.(3)(b)(1), and 4.a.(3)(b)(2) would be consolidated into new Memorandum item 4.a.(1) for the
unpaid principal balance of loans secured by 1-4 family residential properties measured at fair
value, while existing Memorandum items 4.a.(1), 4.a.(2), 4.a.(4), and 4.a.(5) would be
consolidated into new Memorandum item 4.a.(2) for the unpaid principal balance of all other
loans secured by real estate measured at fair value. Existing Memorandum items 4.c.(1) through
4.c.(4) would be consolidated into new Memorandum item 4.c for the unpaid principal balance
of all consumer loans measured at fair value.10
In addition, the agencies propose to remove the separate reporting of fair value detail on
federal funds sold and securities purchased under agreements to resell in item 2, which would
instead be included as part of all other assets in item 6. The agencies also propose to remove the
separate reporting of fair value detail for federal funds purchased and securities sold under
agreements to repurchase in item 9, other borrowed money in item 11, and subordinated notes
and debentures in item 12, with these categories of liabilities instead being reported within all
other liabilities in item 13. The agencies are proposing these changes because they no longer
need the current level of detail on loans measured at fair value under a fair value option and on
certain other fair values in the Call Report from institutions that file the FFIEC 041.
Schedule RC-S
With respect to Schedule RC-S of the FFIEC 041, the agencies propose the following
revisions to Schedule RC-S as they no longer need the current level of detail on securitization
and asset sale activities in the Call Report from institutions that file the FFIEC 041:
(a) Consolidate columns B through F of items 1 through 5 and items 9 through 12, which
collect information on certain securitization and asset sale activities, into existing column
G. The activities covered in columns B through F pertain to home equity lines, credit
card receivables, auto loans, other consumer loans, and commercial and industrial loans,
respectively. The amounts previously reported in columns B through F would be
included in column G, “All other loans, all leases, and all other assets.”
(b) Consolidate the maximum amount of credit exposures arising from recourse or other
seller-provided credit enhancements in the form of retained interest-only strips,
subordinated securities and other residual interests, and standby letters of credit and other
10

In the June 2017 Call Report proposal, the agencies proposed comparable consolidation of the detail on loans
held for trading, which are measured at fair value, and the unpaid principal balance of such loans in Schedule RC-D.

10

(c)

(d)

(e)

(f)

(g)
(h)

(i)

enhancements, which are reported in items 2.a, 2.b, and 2.c, respectively, into a single
new item 2.
Remove item 3 for unused commitments to provide liquidity to structures reported in
item 1 involving assets sold and securitized by the reporting bank with servicing retained
or with recourse or other seller-provided credit enhancements.
Consolidate ownership (or seller’s) interests carried as securities and loans, which are
reported in items 6.a and 6.b, respectively, into a single new item 6, and consolidate
columns B, C, and F, which pertain to home equity lines, credit card receivables, and
commercial and industrial loans, respectively, into column G. The amounts previously
reported in columns B, C, and F would be included in the new item 6 in column G, “All
other loans, all leases, and all other assets.” The agencies also propose to create a
reporting threshold of $10 billion or more in total assets for reporting this new combined
item 6.
Remove items 7.a and 7.b, which contain loan amounts included in ownership (or
seller’s) interests carried as securities that are 30-89 days past due and 90 days or more
past due, respectively.
Remove items 8.a and 8.b, which contain charge-offs and recoveries, respectively, on
loan amounts included in the ownership (or seller’s) interests carried as securities that are
currently reported in item 6.a.
Create a reporting threshold of $10 billion or more in total assets for reporting item 10 on
unused commitments to provide liquidity to other institutions’ securitization structures.
Remove Memorandum items 1.a. and 1.b, which contain the outstanding principal
balance and the amount of retained recourse, respectively, on small business obligations
transferred with recourse under Section 208 of the Riegle Community Development and
Regulatory Improvement Act of 1994. The amounts previously reported in
Memorandum items 1.a and 1.b would be included in items 1 and 2 or items 11 and 12 of
column G depending on whether the obligations that had been sold were securitized or
not securitized, respectively.
Create a reporting threshold of $10 billion or more in total assets for reporting detail on
asset-backed commercial paper (ABCP) conduits in Memorandum items 3.a.(1) through
3.b.(2), and the amount of outstanding credit card fees and finance charges included in
credit card receivables sold and securitized with servicing retained or with recourse or
other seller-provided credit enhancements in Memorandum item 4. To complete
Memorandum item 4, an institution with $10 billion or more in total assets would also
need to meet one of the existing criteria for reporting this information, i.e., the institution,
together with affiliated institutions, has outstanding credit card receivables that exceed
$500 million as of the report date, or the institution is a credit card specialty bank as
defined for Uniform Bank Performance Report (UBPR) purposes.

Schedule RC-T
With respect to Schedule RC-T of the FFIEC 041, the agencies propose to increase the
reporting threshold for reporting the components of fiduciary and related services income. For
institutions with total fiduciary assets greater than $100 million but less than or equal to $250

11

million that do not meet the fiduciary income test for quarterly reporting,11 the agencies propose
to no longer require the reporting of items 14 through 26. There would be no change to the
reporting requirements applicable to items 14 through 26 for all other institutions. The agencies
no longer need the current level of detail on fiduciary and related services income from
institutions with less than $250 million in total fiduciary assets that do not meet the fiduciary
income test.
In addition, the agencies propose to add a reporting threshold for reporting the number
and market value of collective investment funds and common trust funds by type of fund in
Memorandum items 3.a through 3.g. For institutions at which these funds have a total market
value of less than $1 billion (as of the preceding December 31), the agencies propose to no
longer require the reporting of Memorandum items 3.a through 3.g. Such institutions would
report only the total number and market value of their collective investment funds and common
trust funds in Memorandum item 3.h. Institutions at which the total market value of their
collective investment funds and common trust funds is $1 billion or more would continue to
report Memorandum items 3.a through 3.h. The agencies no longer need the current level of
detail on collective investment funds and common trust funds in the Call Report from institutions
at which the total market value of these funds is less than $1 billion.
Schedule RC-V
With respect to Schedule RC-V of the FFIEC 041, the agencies propose to consolidate
information collected on consolidated variable interest entities (VIEs) used as ABCP conduits
(column B) and other VIEs (column C) for all items into a single column B covering all VIEs
other than those used as securitization vehicles (which will continue to be reported in column
A). In lieu of the detailed breakdown of assets and liabilities of ABCP conduit VIEs currently
reported in column B, the agencies propose to collect data only on the total assets and total
liabilities of such VIEs in new items 5 and 6, respectively. For these ABCP conduit VIEs, the
total assets item would include the assets that can be used only to settle these VIEs’ obligations,
which are currently reported in items 1.a through 1.k, column B, and all other assets of these
VIEs, which are currently reported in item 3, column B; the total liabilities items would include
these VIEs’ liabilities for which creditors do not have recourse to the general credit of the
reporting bank, which are currently reported in items 2.a through 2.e, column B, and all other
liabilities of these VIEs, which are currently reported in item 4, column B.
In the two columns of Schedule RC-V that would remain, the agencies also propose to
consolidate the VIE information on held-to-maturity and available-for-sale securities in items 1.b
and 1.c, respectively, into a single new item 1.b; loans and leases held for sale, loans and leases
held for investment, and the allowance for loan and leases losses in items 1.e through 1.g into a
single new item 1.c; and commercial paper and other borrowed money in items 2.c and 2.d,
respectively, into a single new item 2.a. In addition, the agencies propose to remove the VIE
detail on securities purchased under agreements to resell in item 1.d, trading assets (other than
derivatives) in item 1.h, and derivative trading assets in item 1.i. The data currently reported in
these items would be included in existing item 1.k for other assets, which would be renumbered
11

An institution does not meet the fiduciary income test if its gross fiduciary and related services income was less
than or equal to 10 percent of revenue (net interest income plus noninterest income) for the preceding calendar year.

12

as item 1.e. The agencies also propose to remove the VIE detail on securities sold under
agreements to repurchase in item 2.a and derivative trading liabilities in item 2.b; these items
would be included in existing item 2.e for other liabilities, which would be renumbered as
item 2.b. The agencies propose to consolidate and remove these items because they no longer
need the current level of detail on consolidated VIEs in the Call Report.
C. Revisions to the FFIEC 031
Schedule RC-A
With respect to Schedule RC-A of the FFIEC 031, the agencies propose to consolidate
the reporting of an institution’s balances due from depository institutions in the United States,
which are currently reported for the consolidated bank in items 2.a for balances due from U.S.
branches and agencies of foreign banks and 2.b for balances due from other commercial banks
and other depository institutions in the United States, into a single item 2 in column A. In
addition, the agencies propose to consolidate the reporting of an institution’s balances due from
banks in foreign countries and foreign central banks, which are currently reported for the
consolidated bank in items 3.a for balances due from foreign branches of other U.S. banks and
3.b for balances due from banks in foreign countries and foreign central banks, into a single item
3 in column A. The agencies no longer need the current level of detail for these balances in the
Call Report.
Schedule RC-F
With respect to Schedule RC-F of the FFIEC 031, the agencies propose to consolidate the
reporting of an institution’s interest-only strips receivable, which are currently reported in items
3.a for those on mortgage loans and 3.b for those on other financial assets, into a single item 3.
The agencies no longer need the current level of detail for these holdings in the Call Report.
In addition, the agencies propose to remove the preprinted caption for retained interests in
accrued interest receivable related to securitized credit cards (item 6.d) as few institutions report
having this component of other assets in an amount in excess of the existing reporting threshold
for disclosing this component.12 Items 6.e through 6.k would be renumbered as items 6.d
through 6.j.
Schedule RC-H
With respect to Schedule RC-H of the FFIEC 031, in connection with removing the
separate detail for loans held for investment and held for sale in domestic offices measured at fair
value under a fair value option from Schedule RC-Q, the agencies propose to aggregate all loans
held for investment and held for sale in domestic offices measured at fair value under a fair value
option that are currently reported on Schedule RC-Q, column B, Memorandum items 3.a.(1)
through 3.d (including all subitems), into a single new item, Schedule RC-H, item 22. This item
12

If this preprinted caption were removed and an institution has retained interests in accrued interest receivable
related to securitized credit cards in an amount in excess of the reporting threshold, the institution would itemize and
describe this component in one of the subitems of item 6 without a preprinted caption.

13

would be completed by institutions that (1) have elected to report financial instruments or
servicing assets and liabilities at fair value under a fair value option with changes in fair value
recognized in earnings, or (2) are required to complete Schedule RC-D, Trading Assets and
Liabilities. The agencies believe relocating this data from Schedule RC-Q to Schedule RC-H
will improve efficiency by consolidating additional domestic office information on
Schedule RC-H.
Schedule RC-N
With respect to Schedule RC-N of the FFIEC 031, the agencies propose to remove the
data items for reporting the past due and nonaccrual status of the fair value and unpaid principal
balance of held-for-investment loans measured at fair value, which are currently reported in
Memorandum items 5.b.(1) and 5.b.(2), columns A through C. The agencies no longer need this
current level of detail in the Call Report. The agencies would renumber Memorandum item 5.a,
“Loans and leases held for sale,” as Memorandum item 5 for columns A through C.
Schedule RC-P
With respect to Schedule RC-P of the FFIEC 031, the agencies propose to modify the
reporting criteria for this schedule by removing the current $1 billion asset-size threshold and
applying only the existing activity-based threshold to all institutions, regardless of size. As
proposed, Schedule RC-P would be completed by institutions where any of the following
residential mortgage banking activities (in domestic offices) exceeds $10 million for two
consecutive quarters:
 Closed-end and open-end first lien and junior lien 1-4 family residential mortgage loan
originations and purchases for resale from all sources during a calendar quarter; or
 Closed-end and open-end first lien and junior lien 1-4 family residential mortgage loan
sales during a calendar quarter; or
 Closed-end and open-end first lien and junior lien 1-4 family residential mortgage loans
held for sale or trading at calendar quarter-end.
The agencies believe an activity-based threshold alone is more appropriate than an asset-size
threshold for determining which institutions should file this schedule.
The agencies also propose to consolidate the 1-4 family residential mortgage banking
activity detail collected in this schedule for closed-end loans and commitments under open-end
loans for retail originations (item 1), wholesale originations and purchases (item 2), mortgage
loans sold (item 3), mortgage loans held for sale or trading (item 4), and repurchases and
indemnifications of mortgage loans (item 6). Specifically, items 1.a, 1.b, and 1.c.(1) would be
combined into new item 1; items 2.a, 2.b, and 2.c.(1) would be combined into new item 2; items
3.a, 3.b, and 3.c.(1) would be combined into new item 3; items 4.a, 4.b, and 4.c.(1) would be
combined into new item 4; and, items 6.a, 6.b, and 6.c.(1) would be combined into new item 6.
The agencies also propose to consolidate noninterest income from the sale, securitization, and
servicing of closed-end and open-end 1-4 family residential mortgage loans currently reported in
items 5.a and 5.b into a new item 5. In addition, the agencies propose to remove detail on the
principal amount funded for open-end loans extended under lines of credit for each of the above
listed categories currently reported in items 1.c.(2), 2.c.(2), 3.c.(2), 4.c.(2), and 6.c.(2). The

14

agencies are proposing these changes because they no longer need the current level of detail on
1-4 family residential mortgage banking activities in the Call Report.
Schedule RC-Q
With respect to Schedule RC-Q of the FFIEC 031, the agencies propose to modify the
reporting criteria for this schedule by applying only an activity threshold and not an asset-size
threshold, which currently is $500 million. As proposed, Schedule RC-Q would be completed
only by institutions that (1) have elected to report financial instruments or servicing assets and
liabilities at fair value under a fair value option with changes in fair value recognized in earnings,
or (2) are required to complete Schedule RC-D, Trading Assets and Liabilities. Institutions that
do not meet either of these criteria would no longer need to complete this schedule, regardless of
asset size. The agencies believe the activity thresholds are more appropriate than the existing
simple asset-size threshold for determining which institutions must complete this schedule.
For loans held for investment and held for sale measured at fair value under a fair value
option, the agencies also propose to remove column B (domestic offices) for the fair value and
the unpaid principal balance of such loans currently collected in Memorandum items 3 and 4 of
this schedule, respectively, and replace the detailed data on fair value option loans in domestic
offices with a single new item for the total amount of fair value option loans that would be added
to Schedule RC-H, Selected Balance Sheet Items for Domestic Offices.13 In addition, the
agencies would consolidate certain existing loan categories in Memorandum items 3 and 4. For
fair value option loans secured by 1-4 family residential properties, detail on revolving, open-end
loans secured by 1-4 family residential properties and extended under lines of credit; closed-end
loans secured by first liens on 1-4 family residential properties; and closed-end loans secured by
junior liens on 1-4 family residential properties that is currently reported for domestic offices in
column B would be consolidated into a single category and collected for the consolidated bank.
For fair value option loans secured by real estate other than 1-4 family residential properties,
detail on construction, land development, and other land loans; loans secured by farmland; loans
secured by multifamily (5 or more) residential properties; and loans secured by nonfarm
nonresidential properties that is currently reported for domestic offices in column B would be
consolidated into a single category and collected for the consolidated bank. These proposed
revisions would replace the existing items for total fair value option loans secured by real estate
for the consolidated bank. For fair value option consumer loans, detail for the consolidated bank
on credit cards, other revolving credit plans, automobile loans, and other consumer loans would
be consolidated into a single category. Specifically, existing Memorandum items 3.a and 4.a in
column A for the fair value and the unpaid principal balance of the consolidated bank’s total
loans secured by real estate would be removed. Existing Memorandum items 3.a.(3)(a),
3.a.(3)(b)(1), and 3.a.(3)(b)(2) in column B would be consolidated into new Memorandum item
3.a.(1) for the fair value of the consolidated bank’s loans secured by 1-4 family residential
properties measured at fair value, while existing Memorandum items 3.a.(1), 3.a.(2), 3.a.(4), and
3.a.(5) in column B would be consolidated into new Memorandum item 3.a.(2) for the fair value
of all other loans secured by real estate measured at fair value for the consolidated bank.
Existing Memorandum items 3.c.(1) through 3.c.(4) for the consolidated bank would be
consolidated into new Memorandum item 3.c for the fair value of all consumer loans measured at
13

The new Schedule RC-H item would be completed only by institutions required to complete Schedule RC-Q.

15

fair value. Similarly, existing Memorandum items 4.a.(3)(a), 4.a.(3)(b)(1), and 4.a.(3)(b)(2) in
column B would be consolidated into new Memorandum item 4.a.(1) for the unpaid principal
balance of the consolidated bank’s loans secured by 1-4 family residential properties measured at
fair value, while existing Memorandum items 4.a.(1), 4.a.(2), 4.a.(4), and 4.a.(5) in column B
would be consolidated into new Memorandum item 4.a.(2) for unpaid principal balance of all
other loans secured by real estate measured at fair value for the consolidated bank. Existing
Memorandum items 4.c.(1) through 4.c.(4) for the consolidated bank would be consolidated into
new Memorandum item 4.c for unpaid principal balance of all consumer loans measured at fair
value.14 The agencies are proposing these changes because they no longer need the current level
of detail on loans measured at fair value under a fair value option in the Call Report from
institutions that file the FFIEC 031.
Schedule RC-S
With respect to Schedule RC-S of the FFIEC 031, the agencies propose the following
revisions to Schedule RC-S, as they no longer need the current level of detail on securitization
and asset sale activities in the Call Report from institutions that file the FFIEC 031:
(a) Consolidate the maximum amount of credit exposures arising from recourse or other
seller-provided credit enhancements in the form of retained interest-only strips,
subordinated securities and other residual interests, and standby letters of credit and other
enhancements, which are reported in items 2.a, 2.b, and 2.c, respectively, into a single
new item 2.
(b) Create a reporting threshold of $100 billion or more in total assets for item 3, which is
used for reporting unused commitments to provide liquidity to structures reported in item
1 involving assets sold and securitized by the reporting bank with servicing retained or
with recourse or other seller-provided credit enhancements.
(c) Consolidate ownership (or seller’s) interests carried as securities and loans, which are
reported in items 6.a and 6.b, respectively, into a single new item 6. The agencies also
propose to create a reporting threshold of $10 billion or more in total assets for reporting
this new combined item 6.
(d) Remove items 7.a and 7.b, which contain loan amounts included in ownership (or
seller’s) interests carried as securities that are 30-89 days past due and 90 days or more
past due, respectively.
(e) Remove items 8.a and 8.b, which contain charge-offs and recoveries, respectively, on
loan amounts included in the ownership (or seller’s) interests carried as securities that are
currently reported in item 6.a.
(f) Consolidate columns B and C of item 9, which contain the maximum amount of credit
exposure arising from credit enhancements in the form of standby letters of credit,
purchased subordinated securities, and other enhancements provided by the reporting
institution to other institutions’ securitization structures, into existing column G. The
activities covered in columns B and C pertain to home equity lines and credit card
receivables, respectively. The amounts previously reported in columns B and C would be
included in column G, “All other loans, all leases, and all other assets.”

14

In the June 2017 Call Report proposal, the agencies proposed comparable consolidation of the detail on loans
held for trading, which are measured at fair value, and the unpaid principal balance of such loans in Schedule RC-D.

16

(g) Create a reporting threshold of $10 billion or more in total assets for reporting unused
commitments to provide liquidity to other institutions’ securitization structures in item
10. The agencies also propose to consolidate columns B and C of item 10 into existing
column G. The activities covered in columns B and C pertain to home equity lines and
credit card receivables, respectively. The amounts previously reported in columns B and
C by institutions with $10 billion or more in total assets would be included in column G,
“All other loans, all leases, and all other assets.”
(h) Consolidate columns B through F of item 11, which contain assets sold with recourse or
other seller-provided credit enhancements and not securitized, into existing column G.
The activities covered in columns B through F pertain to home equity lines, credit card
receivables, auto loans, other consumer loans, and commercial and industrial loans,
respectively. The amounts previously reported in columns B through F would be
included in column G, “All other loans, all leases, and all other assets.”
(i) Consolidate columns B through F of item 12, which contain the maximum amount of
credit exposure arising from recourse or other seller-provided credit enhancements on
assets sold with recourse or other seller-provided credit enhancements and not
securitized, into existing column G. The activities covered in columns B through F
pertain to home equity lines, credit card receivables, auto loans, other consumer loans,
and commercial and industrial loans, respectively. The amounts previously reported in
columns B through F would be included in column G, “All other loans, all leases, and all
other assets.”
(j) Remove Memorandum items 1.a. and 1.b which contain the outstanding principal balance
and the amount of retained recourse, respectively, on small business obligations
transferred with recourse under Section 208 of the Riegle Community Development and
Regulatory Improvement Act of 1994. The amounts previously reported in these two
memorandum items would be included in items 1 and 2 (column F) or items 11 and 12
(column G) depending on whether the obligations that had been sold were securitized or
not securitized, respectively.
(k) Create a reporting threshold of $10 billion or more in total assets for reporting detail on
ABCP conduits in Memorandum items 3.a.(1) through 3.b.(2), and the amount of
outstanding credit card fees and finance charges included in credit card receivables sold
and securitized with servicing retained or with recourse or other seller-provided credit
enhancements in Memorandum item 4. To complete Memorandum item 4, an institution
with $10 billion or more in total assets would also need to meet one of the existing
criteria for reporting this information, i.e., the institution, together with affiliated
institutions, has outstanding credit card receivables that exceed $500 million as of the
report date, or the institution is a credit card specialty bank as defined for UBPR
purposes.

Schedule RC-T
With respect to Schedule RC-T of the FFIEC 031, the agencies propose to increase the
reporting threshold for reporting the components of fiduciary and related services income. For
institutions with total fiduciary assets greater than $100 million but less than or equal to $250

17

million that do not meet the fiduciary income test for quarterly reporting,15 the agencies propose
to no longer require the reporting of items 14 through 26. There would be no change to the
reporting requirements applicable to items 14 through 26 for all other institutions. The agencies
no longer need the current level of detail on fiduciary and related services income from
institutions with less than $250 million in total fiduciary assets that do not meet the fiduciary
income test.
In addition, the agencies propose to add a reporting threshold for reporting the number
and market value of collective investment funds and common trust funds by type of fund in
Memorandum items 3.a through 3.g. For institutions at which these funds have a total market
value of less than $1 billion (as of the preceding December 31), the agencies propose to no
longer require the reporting of Memorandum items 3.a through 3.g. Such institutions would
report only the total number and market value of their collective investment funds and common
trust funds in Memorandum item 3.h. Institutions at which the total market value of their
collective investment funds and common trust funds is $1 billion or more would continue to
report Memorandum items 3.a through 3.h. The agencies no longer need the current level of
detail on collective investment funds and common trust funds in the Call Report from institutions
at which the total market value of these funds is less than $1 billion.
Schedule RC-V
With respect to Schedule RC-V of the FFIEC 031, the agencies propose to consolidate
information collected on consolidated VIEs used as ABCP conduits (column B) and other VIEs
(column C) for all items into a single column B covering all VIEs other than those used as
securitization vehicles (which will continue to be reported in column A). In lieu of the detailed
breakdown of assets and liabilities of ABCP conduit VIEs currently reported in column B, the
agencies propose to collect data on the total assets and total liabilities of such VIEs in new items
5 and 6, respectively. For these ABCP conduit VIEs, the total assets item would include the
assets that can be used only to settle these VIEs’ obligations, which are currently reported in
items 1.a through 1.k, column B, and all other assets of these VIEs, which are currently reported
in item 3, column B; the total liabilities items would include these VIEs’ liabilities for which
creditors do not have recourse to the general credit of the reporting bank, which are currently
reported in items 2.a through 2.e, column B, and all other liabilities of these VIEs, which are
currently reported in item 4, column B.
In the two columns of Schedule RC-V that would remain, the agencies also propose to
consolidate the VIE information on held-to-maturity and available-for-sale securities in items 1.b
and 1.c into a single new item 1.b; loans and leases held for sale, loans and leases held for
investment, and the allowance for loan and leases losses in items 1.e through 1.g into a single
new item 1.c; and commercial paper and other borrowed money in items 2.c and 2.d into a single
new item 2.a. In addition, the agencies propose to remove the VIE detail on securities purchased
under agreements to resell in item 1.d, trading assets (other than derivatives) in item 1.h, and
derivative trading assets in item 1.i. The data currently reported in these items would be
included in existing item 1.k for other assets, which would be renumbered as item 1.e. The
15

An institution does not meet the fiduciary income test if its gross fiduciary and related services income was less
than or equal to 10 percent of revenue (net interest income plus noninterest income) for the preceding calendar year.

18

agencies also propose to remove the VIE detail on securities sold under agreements to repurchase
in item 2.a and derivative trading liabilities in item 2.b; these items would be included in existing
item 2.e for other liabilities, which would be renumbered as item 2.b. The agencies propose to
consolidate and remove these items because they no longer need the current level of detail on
consolidated VIEs in the Call Report.
Timing
The agencies propose to make the changes effective beginning with the June 30, 2018,
Call Report. When implementing the burden-reducing Call Report revisions as of the June 30,
2018, report date, institutions may provide reasonable estimates for any new or revised Call
Report data item initially required to be reported as of that date for which the requested
information is not readily available. The specific wording of the captions for the new or revised
Call Report data items discussed in this proposal and the numbering of these data items is subject
to change.
Time Schedule for Information Collection and Publication
The Call Reports are collected quarterly as of the end of the last calendar day of March,
June, September, and December. Less frequent collection of Call Reports would reduce the
Federal Reserve’s ability to identify on a timely basis those banks that are experiencing adverse
changes in their condition so that appropriate corrective measures can be implemented to restore
their safety and soundness. State member banks must submit the Call Reports to the appropriate
Federal Reserve Bank within 30 calendar days following the as-of date; a five-day extension is
available to banks with more than one foreign office.
Aggregate data are published in the Federal Reserve Bulletin and the Annual Statistical
Digest. Additionally, data are used in the Uniform Bank Performance Report (UBPR) and the
Annual Report of the FFIEC. Individual respondent data, excluding confidential information,
are available to the public from the National Technical Information Service in Springfield,
Virginia, upon request approximately twelve weeks after the report date. Data are also available
from the FFIEC Central Data Repository Public Data Distribution (CDR PDD) website
(https://cdr.ffiec.gov/public/). Data for the current quarter are made available, shortly after a
bank’s submission, beginning the first calendar day after the report date. Updated or revised data
may replace data already posted at any time thereafter.
Legal Status
The Board is authorized to collect information on the Call Reports from state member
banks pursuant to section 9 of the Federal Reserve Act, which requires state member banks to
file reports of condition and of the payment of dividends with the Federal Reserve (12 U.S.C.
324). The obligation for state member banks to respond is mandatory.
Most of the information provided on the Call Reports is made public. However, the
following items are confidential: (1) the FDIC deposit insurance assessment information
reported in response to item 2.g on schedule RI-E, (2) the prepaid deposit insurance assessments

19

information reported in response to item 6.f on schedule RC-F, and (3) the information regarding
other data for deposit insurance and FICO assessments reported in response to memorandum
items 6-9, 14-15, and 18 on schedule RC-O. It is possible to reverse engineer an institution’s
Capital, Asset Quality, Management, Earnings, Liquidity, and Sensitivity (CAMELS) rating
based on the data reported under the FDIC deposit insurance assessment data item and the
prepaid deposit insurance assessments data item. If this information were publicly available, it
would be possible to determine the state member bank’s CAMELS rating. As a result, this
information is exempt from disclosure under (b)(8) which specifically exempts from disclosure
information “contained in or related to examination, operating, or condition reports prepared by,
on behalf of, or for the use of an agency responsible for the regulation or supervision of financial
institutions” (5 U.S.C. 552(b)(8)). Additionally, this information can be kept confidential under
section (b)(4) of the Freedom of Information Act (5 U.S.C. 552(b)(4)). The release of this
information and information regarding other data for deposit insurance and FICO assessments
reported in response to memorandum items 6-9, 14-15, and 18 on schedule RC-O would likely
cause substantial harm to the competitive position of the institution from whom the information
was obtained if it was released.
Consultation Outside the Agency and Discussion of Public Comments
On November 8, 2017, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (82 FR 51908) requesting public comment for 60 days on the
extension, with revision, of the Call Reports. The comment period for this notice expired on
January 8, 2018. The agencies collectively received comments on the proposal from five
entities, including banking organizations and a trade association. General comments and
recommendations on the proposal and the overall burden-reduction initiative are included in this
section.
General Comments on the Proposal and the Overall Burden-Reduction Initiative
Commenters expressed varying opinions on the November 2017 notice and the agencies’
Call Report burden-reduction initiatives to date. Two commenters supported the effort put forth
by the agencies. One commenter “strongly support[s] the FFIEC’s ongoing work to reform the
Call Report, an ongoing project that is yielding important value for supervision as well as for
successful bank management.” The other commenter “commends” the agencies’ initiative and
encourages continued efforts to ease the burden on small community banks. One commenter,
however, asserted that the proposed revisions to the Call Reports would not have any impact on
the banking organization’s reporting.
The agencies recognize that not all institutions would see an immediate and large
reduction in burden from the proposed revisions in the November 2017 notice. However,
consolidating existing data items into fewer data items and adding or increasing reporting
thresholds would generally result in institutions spending less time completing the Call Report
since there would be fewer items to review prior to each quarterly submission. Also, an
institution would have fewer instructions to review to determine whether it has reportable
(nonzero) amounts. To the extent that an institution currently tracks granular data items for
internal reporting purposes that are proposed to be consolidated in the Call Report, there may be

20

limited burden relief from consolidating the items. However, institutions that currently track
data at an aggregate level for internal reporting purposes and then must allocate that amount to
the existing subcategories in the Call Report every quarter would see burden relief. Accordingly,
the agencies believe the changes proposed in the November 2017 notice offer meaningful Call
Report burden relief to many institutions.
General Recommendations from Commenters
One commenter offered a number of recommendations to improve the revision and
preparation of the Call Report. Regarding the revision process, the commenter recommended
that the agencies conduct an internal user survey covering every item in the Call Report at least
once every two years, conduct a review for potentially obsolete items at least annually, and
continue to improve the clarity and usability of Call Report instructions. The agencies currently
conduct the user survey as the foundation for a review of all Call Report data items they are
required to conduct every five years.16 The full survey is an involved process requiring
significant agency resources from all lines of business. For the statutorily mandated review of
the Call Report completed in 2017, the full survey spanned a 19-month period. As the agencies
must balance the use of their resources for this effort compared with other efforts to improve
supervision and reduce burden for institutions, the agencies decline to increase the frequency of
the internal user survey.
With respect to the clarity and usability of the Call Report instructions, the agencies agree
with the commenter that making the instructions clearer and providing examples of how to
calculate amounts that may be more complex to report contribute to burden relief. The agencies
welcome suggestions from bankers, industry associations, and others for specific improvements
to and clarifications of the existing instructions, including where examples would be helpful.
Input from these stakeholders and from agency examination staff has led to instructional
improvements in the past and the agencies will continue to address specific suggestions for
instructional improvements. The commenter also cited the benefits of hyperlinks to the rule or
guidance on which particular instructions are based. The agencies have previously added
hyperlinks to certain cited documents in the two sets of Call Report instructions.17 Going
forward, the agencies will endeavor to use clearer language and expect to continue inserting
hyperlinks when issuing new or updated Call Report instructions.
The commenter also recommended that the agencies only propose revisions to the Call
Report once a year, make those changes effective starting in the quarter ending March 31, and
finalize those changes by the prior September 30 to allow banks sufficient lead time to
implement the revisions. Prior to the recent revisions to streamline the Call Report, the agencies
typically followed a schedule of making revisions only once per year, with the changes generally
becoming effective for the March 31 report. The agencies plan to return to an annual schedule
for future revisions that would be effective starting with the March 31 report, unless the revisions
must be implemented at a different time due to changes in statute, regulation, or accounting
standards.
16

See section 604 of the Financial Services Regulatory Relief Act of 2006.
One set of Call Report instructions applies to the FFIEC 031 and FFIEC 041 reports and another set of
instructions applies to the FFIEC 051 report.
17

21

The same commenter recommended that the FFIEC establish an industry advisory
committee to develop advice and guidance on the Call Report, establish a regular process to
address technical questions and changes to the Call Report, and provide training related to
preparing the Call Report. The agencies plan to continue to offer outreach in connection with
significant revisions to the Call Report, as they did with the adoption of the revised Schedule
RC-R, Regulatory Capital, and the implementation of the FFIEC 051. The agencies also receive
and respond to a number of reporting questions from individual institutions each quarter. Issues
that could affect multiple institutions are often addressed through the Call Report Supplemental
Instructions published quarterly or updates to the Call Report instruction books published as
needed. Consistent with the Paperwork Reduction Act, the agencies also offer an opportunity for
members of the banking industry to comment on proposed changes to the Call Report or to make
any additional suggestions for improving, streamlining, or clarifying instructions to the Call
Report.
The commenter also recommended that the agencies align the proposed revisions to the
Call Report with revisions to the Board’s FR Y-9C report for holding companies18 and conduct a
holistic review of other regulatory reports under the agencies’ authority that rely on data
collected in the Call Report. The commenter stated that having differences in reporting between
the Call Report and FR Y-9C can create burden for reporting firms.
The agencies agree that aligning proposed revisions to the Call Report with proposed
revisions to comparable data items collected in the FR Y-9C report would reduce burden for
reporting holding companies.19 The Board has approved burden-reducing revisions to the FR Y9C that align with corresponding burden-reducing revisions that were effective with the
March 31, 2017, Call Report.20 These FR Y-9C revisions became effective as of the
March 31, 2018, reporting date. The Board also has proposed revisions to the FR Y-9C21 that
align with the corresponding revisions to the Call Report that the banking agencies proposed in
June 2017.22 These revisions are proposed to become effective as of the March 31, and June 30,
2018, reporting dates for both the FR Y-9C and Call Report. Further, the Board will take this
comment into consideration when it develops additional proposed revisions to the FR Y-9C
report consistent with other comparable revisions proposed for the Call Report. In addition to
the FR Y-9C, the agencies will consider reviewing how data from the Call Report are used in
other agency reports to identify possible efficiencies as part of a holistic review.

Furthermore, the agencies will consider reviewing existing instructions to other
regulatory reports to identify opportunities to enhance uniformity in reporting guidance. In this
regard, the agencies have already proposed revisions to the FFIEC 002 report that would align

18

Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No. 7100-0128).
Although all insured depository institutions must file Call Reports, not all such institutions are owned or
controlled by a holding company. Furthermore, the FR Y-9C report is filed only by top-tier holding companies with
total consolidated assets of $1 billion or more and top-tier holding companies meeting certain criteria, regardless of
size.
20
See 83 FR 2985 (January 22, 2018).
21
See 83 FR 123 (January 2, 2018).
22
See 82 FR 29147 (June 27, 2017).
19

22

with corresponding revisions that have been implemented or proposed for the Call Report.23
Similarly, in the proposed new FFIEC 016 report that would replace the separate, but identical,
agency stress test reports,24 the agencies have proposed revisions to certain data items in this
report that align with corresponding Call Report revisions that have been implemented or
proposed.
The commenter further recommended that the agencies increase the asset-size threshold
for filing the FFIEC 051 Call Report from the current $1 billion to at least $10 billion, indexed
for inflation. Raising the threshold to $10 billion or higher would result in a significant loss of
data necessary for supervisory or other purposes from institutions with assets of $1 billion or
more, which often are more complex and present greater risk than smaller institutions.
Therefore, the agencies are not adopting this recommendation at this time, but will continue to
evaluate the appropriate scope and criteria for expanding the number of institutions eligible to
file the FFIEC 051.
Specific Recommendations to Revise the Call Report
One commenter requested the agencies eliminate certain deposit items in Schedule RC-E
by combining items for deposits with balances less than $100,000 and those with balances of
$100,000 through $250,000 into a single item. Separate reporting of time deposits with balances
less than $100,000 in Schedule RC-E, including certain Memorandum items to adjust that
amount, is tied to the Board’s measurement of the money supply.25 If the Board were to decide
to revise the definition of the money supply so that the $100,000 items in Schedule RC-E are no
longer necessary for the calculation, then the agencies would reevaluate whether to consolidate
those items on the Call Report.
One commenter recommended that the agencies add a new loan item to Schedule RC-C,
Part I, to enable institutions to report non-speculative 1-4 family residential construction loans to
consumers separately from other 1-4 family residential construction loans.26 The commenter
made this recommendation because the loan mix index used in the FDIC’s deposit insurance
assessment rate determination for small institutions treats all construction and development loans
in the same manner. According to the commenter, consumer 1-4 family residential construction
loans have lower charge-off rates than other types of construction and development loans, which
penalizes institutions that hold significant amounts of such consumer construction loans in terms
of their assessment rates. However, the addition to Schedule RC-C, Part I, of the recommended
new construction loan category would not alter the assessment rate determination. Absent the
segregation by the FDIC of consumer 1-4 family residential construction loans from other
construction loans in the loan mix index in the FDIC’s deposit insurance assessments regulations
23

Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks (FFIEC 002; OMB No. 71000032). See 82 FR 61294 (December 27, 2017).
24
Annual Dodd-Frank Act Company-Run Stress Test Report for Depository Institutions and Holding Companies
with $10-$50 Billion in Total Consolidated Assets (FFIEC 016; OMB No. 7100-0356). See 82 FR 46887 (October
6, 2017) and 83 FR 8149 (February 23, 2018).
25
See definition of M2, https://www.federalreserve.gov/faqs/money_12845.htm. Also see 82 FR 2452 (January 9,
2017) for the agencies’ previous response to a similar comment.
26
All 1-4 family residential construction loans are reported in Schedule RC-C, Part I, item 1.a.(1). Other
construction loans and all land development and other land loans are reported in Schedule RC-C, Part I, item 1.a.(2).

23

(12 CFR part 327), the agencies do not plan to add a new category for reporting such loans in
Schedule RC-C, Part I.
After considering these specific comments, as well as the comments received on the
overall proposal and the burden-reduction initiative, the agencies will proceed with the proposed
burden-reducing changes to Call Report schedules proposed in the November 2017 notice.
While the agencies recognize that not every proposed change will reduce burden for every
institution, the agencies believe that the proposed changes will reduce burden in the Call Reports
as a whole, which is also reflected in a reduction in the estimated burden hours per quarter for
the Call Reports.
On April 11, 2018, the agencies published a final notice in the Federal Register (83 FR
15678).
Estimate of Respondent Burden
The current annual reporting burden for the Call Report is estimated to be 169,861 hours
and would decrease to 163,571 hours as shown in the following table. The average estimated
hours per response for Board Call Report filers would decrease from 51.85 hours to 49.93 hours
due to the proposed changes. The proposed burden reducing revisions are the result of an
ongoing effort by the agencies to reduce the burden associated with the preparation and filing of
Call Reports and, as detailed in Appendices B, C, and D, achieve burden reductions by the
removal or consolidation of numerous items, and the adding a new or raising certain existing
reporting thresholds.
The estimated average burden hours for each agency collectively reflect the estimates for
the FFIEC 031, FFIEC 041, and FFIEC 051 reports. When the estimates are calculated by type
of report across the agencies, the estimated average burden hours per quarter are 122.38
(FFIEC 031), 55.35 (FFIEC 041), and 37.94 (FFIEC 051). The burden hours for the currently
approved reports are 123.06 (FFIEC 031), 57.71 (FFIEC 041), and 39.38 (FFIEC 051), so the
revisions would represent a reduction in estimated average burden hours per quarter by
0.68 (FFIEC 031), 2.36 (FFIEC 041), and 1.44 (FFIEC 051). The estimated burden per response
for the quarterly filings of the Call Report is an average that varies by agency because of
differences in the composition of the institutions under each agency’s supervision (e.g., size
distribution of institutions, types of activities in which they are engaged, and existence of foreign
offices). These reporting requirements represent 1.5 percent of the total Federal Reserve
paperwork burden.

24

Number of
respondents27

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current

819

4

51.85

169,861

Proposed

819

4

49.93

163,571

FFIEC 031,
FFIEC 041, and
FFIEC 051

Change

(6,290)

The current total annual cost to all state member banks is estimated to be $9,520,709 and
with the proposed revisions would decrease to $9,168,155.28 This estimate represents costs
associated with recurring salary and employee benefits, and expenses associated with software,
data processing, and bank records that are not used internally for management purposes but are
necessary to complete the Call Reports.
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The proposed cost to the Federal Reserve System for collecting and processing the
FFIEC 031, FFIEC 041, and FFIEC 051 is estimated to be $1,871,500 per year, a decrease of
$28,900 from the current cost of $1,900,400. The one-time cost to implement the revised report
is estimated to be $50,800.

27

Of these respondents, 561 are considered small entities as defined by the Small Business Administration (i.e.,
entities with $550 million or less in total assets) www.sba.gov/contracting/getting-started-contractor/make-sure-youmeet-sba-size-standards/table-small-business-size-standards.
28
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$69, 15% Lawyers at $68, and 10% Chief Executives at $94). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2017, published March 30, 2018, www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

25

Appendix A
Summary of the FFIEC Member Entities’ Uses of the Data Items in the
Call Report Schedules in the Portion of the User Surveys Evaluated in the
Development of This Proposal
Schedule RI-A (Changes in Bank Equity Capital)
Schedule RI-A collects detailed information about specified categories of changes in an
institution’s equity capital during the calendar year to date. In general, these categories are
aligned with categories typically reported on a basic statement of changes in equity in a set of
financial statements prepared under U.S. generally accepted accounting principles (GAAP).
The FFIEC member entities’ examiners use the Schedule RI-A information in their offsite reviews to identify and understand the sources of any significant changes in an institution’s
capital accounts. Information on dividends declared as a percentage of net income reveals the
extent to which capital is being augmented through earnings retention, which is the principal
source of capital for most institutions. The banking agencies may be aware of some capital
transactions reported in Schedule RI-A due to licensing requirements. However, for many other
transactions directly affecting capital such as dividends declared and transactions with a parent
holding company, Schedule RI-A may be the only source of information on changes in capital
aside from an on-site examination. Even for capital transactions that require prior agency
approval, the information reported in Schedule RI-A serves as confirmation that the institution
successfully completed the transaction (such as issuing new stock or redeeming existing
preferred stock). The agencies also use the information on this schedule as a starting point for
reviewing compliance with statutory or regulatory restrictions on dividends or holding company
transactions.
The FDIC uses data items from Schedule RI-A in its estimates of losses from failures of
insured depository institutions, which affects the FDIC’s loss reserve and the resulting level of
the balance in the Deposit Insurance Fund.
Schedule RI-C (Disaggregated Data on the Allowance for Loan and Lease Losses) (FFIEC 031
and FFIEC 041 only)
Schedule RI-C provides information on the components of the allowance for loan and
lease losses (ALLL) by loan category disaggregated on the basis of a reporting institution’s
impairment measurement method and the related recorded investment in loans (and, as
applicable, leases) held for investment for institutions with $1 billion or more in total assets. The
information required to be reported in Schedule RI-C is consistent with disclosures required
under existing U.S. GAAP in Financial Accounting Standards Board (FASB) Accounting
Standards Codification (ASC) paragraphs 310-10-50-11B(g) and (h).
By providing this level of detail on an individual institution’s overall ALLL, which
supports the identification of changes in its components over time, examiners can better perform
off-site monitoring of activity within the ALLL in periods between examinations and when

26

planning for examinations. Thus, the Schedule RI-C information enables examiners and agency
analysts to determine whether the institution is releasing loan loss allowances in some loan
categories and building allowances in others. Furthermore, changes from period to period in the
volume of individually evaluated loans that have been determined to be impaired in each loan
category, and the allowance allocations to these impaired loans, provide examiners and analysts
with an indicator of trends in the institution’s credit quality. This understanding is critical to the
agencies since the ALLL, and the direction of changes in its composition, is one of the key
factors in determining an institution’s financial condition.
The detailed ALLL information collected in Schedule RI-C allows the agencies to more
finely focus efforts related to the analysis of the ALLL and credit risk management. By
reviewing the data collected in Schedule RI-C on allowance allocations by loan category in
conjunction with the past due and nonaccrual data reported by loan category (in Schedule RC-N)
that are used in a general assessment of an institution’s credit risk exposures, the agencies can
better evaluate whether the overall level of its ALLL, and its allocations by loan category, appear
appropriate or whether supervisory follow-up is warranted. Together, the ALLL information and
past due and nonaccrual data factor into the assessment of the Asset Quality component of the
CAMELS rating.29 As an example, by using the detailed information on the ALLL allocated to
commercial real estate (CRE) loans, examiners and analysts can better understand how
institutions with CRE concentrations are building or releasing allowances, the extent of ALLL
coverage in relation to their CRE portfolios, and how this might differ among institutions.
Schedule RI-C also assists the agencies in understanding industry trends related to the
build-up or release of allowances for specific loan categories. The information supports
comparisons of ALLL levels by loan category, including the identification of differences in
ALLL allocations by institution size. Understanding how institutions’ ALLL practices and
allocations differ over time for particular loan categories as economic conditions change
provides insight that can be used to more finely tune supervisory procedures and policies.
Schedule RC-A (Cash and Balances Due from Depository Institutions) (FFIEC 031 and
FFIEC 041 only)
Schedule RC-A provides data on currency and coin, cash items, balances due from U.S.
and foreign depository institutions, and balances due from Federal Reserve Banks. This
information, particularly from larger institutions, is utilized for monetary policy purposes and
liquidity analysis purposes.
For monetary policy purposes, information from Schedule RC-A is needed for analysis of
the relationship between institutions’ cash assets and the federal funds market, and in the
construction of the monetary aggregates and weekly estimates of cash assets. The Board, in
conducting monetary policy, monitors shifts between cash accounts and federal funds as a
measure of the effectiveness of policy initiatives. For example, differences in interest rates paid
on balances due from Federal Reserve Banks compared to those available in the federal funds
29

CAMELS is an acronym that represents the ratings from six essential components of an institution’s financial
condition and operations: capital adequacy, asset quality, management, earnings, liquidity, and sensitivity to market
risk. These components represent the primary areas evaluated by examiners during examinations of institutions.

27

market cause shifts in the relative volumes of funds institutions hold in their Federal Reserve
Bank accounts and federal funds sold. This can be seen in the significant shrinkage in the federal
funds market over the past ten years that has been offset by increases in cash assets held. As
monetary policy normalizes and rates in the federal funds market increase, data in Schedule RCA will allow the Board to analyze how cash assets would change as the federal funds market
responds to the movement in rates.
Schedule RC-A data also serve as inputs into the construction of the monetary aggregates
and in deriving estimates of cash assets on a weekly frequency. Cash items reported in item 1
are utilized as netting components in constructing the monetary aggregates. Items for cash and
balances due from depository institutions are utilized to benchmark comparable weekly data
collected by the Board from a sample of both small and large depository institutions. These
weekly estimates provide timely input for more effective monitoring of institutions’ cash asset
positions.
Schedule RC-A provides information about the most liquid balance sheet accounts
available to satisfy unexpected cash outflows. Thus, information reported on balances due from
depository institutions, including those representing correspondent banking balances, are a key
element in the agencies’ analysis of an institution’s management of liquidity risk. Such balances
serve to pay the institution’s daily cash letters and must be maintained at sufficient levels to
cover these obligations in the normal course of business. At the same time, information from
Schedule RC-A is particularly important for the agencies’ evaluations of an institution’s ability
to effectively respond to liquidity stress. Although other balance sheet assets, such as debt
securities, are secondary sources of liquidity under normal operating conditions, examiners
consider the availability of on-balance sheet cash and due from balances under a highly stressed
operating environment. Given the volatility of liability funding sources, agency supervisory staff
assess the demands of a potential liquidity crisis in comparison to the availability of funds from
due from balances. Because the amount of liquid assets that an institution should maintain is a
function of the stability of its funding structure and the risk characteristics of its balance sheet
and off-balance sheet activities, examiners monitor the level of cash and due from balances, and
changes therein from period to period, by using data from Schedule RC-A as part of their off-site
analyses of liquidity risk. The results of these analyses may influence the supervisory strategy
for an institution and is an input into examination planning activities necessary for scoping and
staffing the evaluation of liquidity and funds management during examinations.
The separate breakout of balances due from banks in foreign countries and foreign central
banks in Schedule RC-A also aids the agencies in assessing liquidity risk arising from additional
or distinct banking laws and regulations in foreign countries and in evaluating the currency risk
and country risk associated with these balances.
Schedule RC-F (Other Assets)
Schedule RC-F collects a breakdown of assets not reported in other balance sheet asset
categories, such as deferred tax assets, equity securities without readily determinable fair values,
and life insurance assets. This information is used in off-site monitoring and for pre-examination
planning. A trend of rapid growth in or a significant change in the reported amount of an

28

individual category of other assets that is identified through off-site monitoring may represent an
area of potential concern or heightened risk and require further review and assessment, either
upon identification or at the next examination.
For example, a significant increase in the level of accrued interest receivable may be
indicative of deterioration in the repayment capacity of an institution’s borrowers or a relaxation
of management’s loan collection policies and practices, which would signal an increase in
overall credit risk. Growth in the amount of net deferred tax assets, particularly at an institution
with cumulative losses in recent years, raises questions about the realizability of these assets and
whether the need for a valuation allowance has been properly assessed. The importance of
ensuring the appropriateness of the reported amount of these assets is also tied to the deductions
and limits that apply to deferred tax assets under the agencies’ regulatory capital rules.
Examiners use information on the volume of interest-only strips receivable in their preexamination scoping of an institution’s interest rate risk to determine the extent of this risk in
preparation for an on-site assessment. Because bank-owned life insurance exposes an institution
to liquidity, operational, credit, interest rate, and other risks, examiners need to identify
significant holdings of life insurance assets and growth in such holdings. In these circumstances,
examiners evaluate management’s adherence to prudent concentration limits for life insurance
assets and management’s performance of comprehensive assessments of the risks of these assets,
either on an off-site basis or during examinations.
Information on those individual components of all other assets that exceed the Schedule
RC-F disclosure threshold helps examiners evaluate the significance of these items to the overall
composition of the balance sheet and identify risk exposures associated with these assets. For
example, when examiners find the reported amount of repossessed assets at an institution to be
increasing, these data, taken together with data on the volume of past due and nonaccrual loans
reported in Schedule RC-N, may signal credit deterioration and the need for examiner follow-up
with management. Data on repossessed assets also are used for the scoping of targeted consumer
compliance examinations, particularly with respect to auto loan origination and servicing.
Data on accrued interest receivable also are used in the FDIC’s model that estimates
losses arising from the failure of problem institutions, which affects the measurement of the
balance of the Deposit Insurance Fund.
Schedule RC-G (Other Liabilities)
Schedule RC-G collects a breakdown of liabilities not reported in other balance sheet
liability categories, such as interest accrued and unpaid on deposits, net deferred tax liabilities,
and the allowance for credit losses on off-balance sheet exposures. As with the other assets data
collected in Schedule RC-F, information reported in Schedule RC-G is used in off-site
monitoring and for pre-examination planning. A trend of rapid growth in or a significant change
in the reported amount of an individual category of other liabilities that is identified through offsite monitoring may represent an area of potential concern or heightened risk and require further
review and assessment, either upon identification or at the next examination.
For example, a significant increase or decrease in the interest accrued and unpaid on

29

deposits would warrant examiner follow-up to determine the cause for this change from previous
levels because it could indicate a change in an institution’s funding strategy with a consequential
effect on its future earnings and its interest rate risk exposure. Examiner assessments of material
increases in the allowance for off-balance sheet credit exposures are performed to determine
whether this reflects credit quality deterioration on the part of existing customers to whom credit
has been extended, a loosening of underwriting practices for granting or renewing lines of credit,
or other factors, especially at banks with significant credit card operations or other unfunded
commitments.
Information on those individual components of all other liabilities that exceed the
Schedule RC-G disclosure threshold helps examiners evaluate the significance of these items to
the overall composition of the balance sheet and identify risk exposures associated with these
liabilities. For example, an increase in the amount of derivatives with negative fair values,
considering changes in the notional amounts of derivatives reported in Schedule RC-L (on the
FFIEC 031 or FFIEC 041) or Schedule SU (on the FFIEC 051), would lead to examiner review
of an institution’s hedging activities and their effectiveness in offsetting identified hedged risks
or its strategy for entering into derivatives transactions for purposes other than hedging because
of the resulting negative impact on earnings. Because deferred compensation liabilities create
funding obligations, growth in the amount of these liabilities that triggers disclosure in Schedule
RC-G warrants examiner review to ensure that management is properly planning for the funding
mechanisms to be used to satisfy these compensation arrangements.
Data on interest accrued and unpaid on deposits also are used in the FDIC’s model that
estimates losses arising from the failure of problem institutions, which affects the measurement
of the Deposit Insurance Fund.
Schedule RC-H (Selected Balance Sheet Items for Domestic Offices) (FFIEC 031 Only)
Schedule RC-H provides data on selected balance sheet items held in domestic offices
only, and complements domestic office information collected in Schedule RC-C, Part I (Loans
and Leases), Column B, and in Schedule RC-A (Cash and Balances Due from Depository
Institutions), Column B. This domestic office level information is utilized for monetary policy
and supervisory risk assessment purposes.
In general, Board policymakers set U.S. monetary policy to influence economic activity
and financial market conditions in the United States. The domestic office components of the
balance sheet items in Schedule RC-H and elsewhere in the Call Report are used in this context
to assess credit availability, banks’ funding patterns, liquidity, and investment strategies in the
United States. For example, if the level of an institution’s consolidated holdings of U.S.
Treasury securities were increasing, but upon further review a significant portion of the growth
reflected a rise in the amount of the institution’s securities that are held in its foreign offices,
such growth would not constitute direct support of either increased liquidity or a change in
investment strategy at the institution’s domestic offices. Moreover, in that case, such growth
would not constitute an increase in the Board’s U.S. bank credit aggregate, which is based on
domestic-office-only holdings of institutions’ securities and loans. Without the domesticoffices-only component of U.S. Treasury securities, the interpretation of increases in such

30

securities holdings would be unnecessarily complicated; it would otherwise be unclear to
policymakers, analysts, and others whether such growth had in fact reflected stimulation of the
U.S. economy in the form of U.S. bank credit.
For institutions with foreign and domestic operations, the division of assets and funding
between foreign and domestic components is a key element of an institution’s risk profile. For
example, the levels of funding and assets at such an institution that are subject to potentially
more restrictive foreign laws and regulations and to currency risk and other transactional risks
define a major portion of the institution’s risk profile. In addition, data on the volume of assets
and liabilities by balance sheet category in domestic versus foreign offices is essential for
planning and staffing examinations of institutions with foreign offices.
Schedule RC-I (Assets and Liabilities of IBFs) (FFIEC 031 Only)
Schedule RC-I requires the reporting, on a fully consolidated basis, of the total assets and
liabilities of all International Banking Facilities (IBFs) established by the reporting institution,
i.e., including any IBFs established by the institution itself or by its Edge or Agreement
subsidiaries. An IBF is a set of asset and liability accounts, segregated on the books and records
of the establishing entity, which reflect permitted international transactions. IBF activities are
essentially limited to accepting deposits from and extending credit to foreign residents (including
banks), other IBFs, and the institutions establishing the IBF. The general purpose of the
collection of these two Schedule RC-I data items is to aid in the planning of examinations on the
risks and activities associated with international lending, financing instruments, and international
banking conducted through an IBF. These two data items also serve as high level indicators of
institutions’ engagement in such activities between examinations. There is no other source of
information on the total assets and liabilities of U.S. banking institutions’ IBFs.
Schedule RC-P (1-4 Family Residential Mortgage Banking Activities in Domestic Offices)
(FFIEC 031 and FFIEC 041 only)
For institutions that meet an activity-based reporting threshold associated with their
mortgage banking activities in domestic offices, Schedule RC-P provides data on their
originations, purchases, and sales of closed-end and open-end 1-4 family residential mortgages
during the quarter. Institutions providing data in Schedule RC-P also report the amount of
closed-end and open-end 1-4 family residential mortgage loans held for sale or trading at quarterend as well as the noninterest income for the quarter from the sale, securitization, and servicing
of these mortgage loans. For open-end mortgage loans, institutions report the total commitment
under the line of credit. These data are collected to enhance the agencies’ ability to monitor the
nature and extent of institutions’ involvement with 1-4 family residential mortgage loans as
originators, sellers, and servicers of such loans.
Since mortgage banking accounts for a large source of income at many institutions,
concentrations of activities in this area pose several types of risks. These risks include
operational, credit, interest rate, and liquidity risks, evaluations of which are critical in assigning
appropriate CAMELS ratings for an institution. Therefore, the agencies monitor and analyze the
Schedule RC-P data on institutions’ mortgage banking activities to support their assessments of

31

various risk components of CAMELS ratings. For example, 1-4 family residential mortgage
banking activities may include an institution’s obligation to repurchase mortgage loans that it has
sold or otherwise indemnify the loan purchaser against loss due to borrower defaults, loan
defects, other breaches of representations and warranties, or other reasons, thereby exposing the
institution to additional risk. To monitor this exposure, Schedule RC-P collects data on 1-4
family residential mortgage loan repurchases and indemnifications during the quarter as well as
representation and warranty reserves for such loans that have been sold. If off-site analysis of
the reported data on repurchases and indemnifications reveals substantial increases in recent
periods, this would be a red flag for supervisory questions about the credit and operational risks
arising from the institution’s mortgage loan originations and purchases as well as its ability to
fund a higher level of loan repurchases going forward than it may be accustomed to repurchase.
Examiner review of the appropriateness of the level of representation and warranty reserves and
the institution’s methodology for estimating the amount of these reserves also would be
warranted.
In addition, the data reported in Schedule RC-P are used in the ongoing monitoring of the
current volume, growth, and profitability of institutions’ 1-4 family residential mortgage banking
activities. In this regard, significant growth in these activities over a short period of time,
particularly in relation to the size of an institution, raises supervisory concerns as to whether the
institution has implemented appropriate risk management processes, controls, and governance
over its mortgage banking business. The extent of the increased level of activity will determine
the nature and timing of the supervisory follow-up. More generally, for examiners, the off-site
monitoring of the Schedule RC-S data and related metrics and trends provides key information
for examination scoping and helps determine the allocation of mortgage-banking specialists’
time during on-site examinations.
A substantial volume of loans and other assets held for sale in a market where the assets
may not be able to be readily sold can cause significant liquidity strain because of the
institution’s need for funding to carry these assets for a greater length of time than had been
anticipated. Thus, the agencies use data from Schedule RC-P when assessing an institution’s
liquidity position by monitoring and analyzing the extent of mortgages held for sale or trading.
If there is significant growth in the amount of such mortgage holdings, particularly when the
Schedule RC-P data reveal larger amounts of originations and purchases compared to sales, this
would be an indicator that the acquired loans are not selling and a basis for supervisory followup.
From a consumer compliance perspective, the agencies use Schedule RC-P data to
monitor mortgage-related metrics for assessing potential risks to consumers, and for the
scheduling and scoping of examinations. Additionally, the agencies rely on Schedule RC-P data
for assessing an institution’s product lines for compliance with the Community Reinvestment
Act and other fair lending regulations, particularly if the institution engages in wholesale
originations of mortgage loans.
Schedule RC-Q – Assets and Liabilities Measured at Fair Value on a Recurring Basis
(FFIEC 031 and FFIEC 041 only)
FASB ASC Topic 820, Fair Value Measurement, provides guidance on how to measure

32

fair value and establishes a three-level hierarchy for measuring fair value. This hierarchy
prioritizes inputs used to measure fair value based on observability, giving the highest priority to
quoted prices in active markets for identical assets or liabilities (Level 1) and the lowest priority
to unobservable inputs (Level 3).
Under ASC Subtopic 825-10, Financial Instruments – Overall, ASC Subtopic 815-15,
Derivatives and Hedging – Embedded Derivatives, and ASC Subtopic 860-50, Transfers and
Servicing – Servicing Assets and Liabilities, an institution may elect to report certain assets and
liabilities at fair value with changes in fair value recognized in earnings. This election is
generally referred to as the fair value option. Under U.S. GAAP, certain other assets and
liabilities are required to be measured at fair value on a recurring basis.
Institutions that have elected to apply the fair value option or have reported $10 million
or more in total trading assets in any of the four preceding calendar quarters must report in
Schedule RC-Q the amount of assets and liabilities, by major categories, that are measured at fair
value on a recurring basis in the financial statements, along with separate disclosure of the
amount of such assets and liabilities whose fair values were estimated under each of the three
levels of the FASB’s fair value hierarchy.
Agency staff use the information on assets reported at fair value in Schedule RC-Q to
calibrate and estimate the impact of regulatory capital policy, as well as evaluate contemplated
capital policy changes. The agencies also use the Schedule RC-Q data (particularly the volume
of fair value option assets and liabilities in relation to total assets and total capital, whether the
volume has significantly increased, and whether the option has begun to be applied to new
categories of assets or liabilities) to assist with planning the proper scoping and staffing of risk
management safety and soundness examinations given the critical importance of robust risk
management and control processes around fair value measurement. For available-for-sale
securities and fair value option loans, agency staff can also compare the fair values reported in
Schedule RC-Q with the amortized cost and unpaid principal balance, respectively, reported for
these assets in the Call Report to understand the extent and direction of these measurement
differences and their potential effect on regulatory capital should a substantial portion of these
assets need to be sold. The agencies also use this information to evaluate the extent of Level 3
fair value measurements of certain assets and liabilities because of the extensive use of
unobservable inputs to estimate these fair values, as well as to monitor trading asset valuations
and shifts in the fair value hierarchy valuation levels among trading assets over time and across
capital markets.
Information in Schedule RC-Q is also used by agency examination staff to analyze
capital, asset quality, earnings, and liquidity components of CAMELS. The agencies also use
data reported in Schedule RC-Q in credit risk management tools. Obtaining these data on a
quarterly basis allows for closer monitoring of credit risk changes affecting assets measured at
fair value. The data are also used to monitor bank performance, emerging trends, and certain
mortgage servicing assets.

33

Schedule RC-S (Servicing, Securitization, and Asset Sale Activities) (FFIEC 031 and
FFIEC 041)
Schedule RC-S collects data on servicing, securitization, and asset sale activities. The
majority of these data represents off-balance sheet activities. The agencies use the data provided
in this schedule primarily for risk identification and examination scoping purposes.
Exposures reported in Schedule RC-S can affect an institution’s liquidity outlook. For
example, if an institution has a commitment to provide liquidity to its own or other institutions’
securitization structures or has provided credit enhancements in the form of recourse or standby
letters of credit for assets it has sold or securitized, the agencies need to consider such funding
commitments to properly monitor and assess the full scope of an institution’s liquidity position.
This schedule also captures past due amounts for loans the reporting institution has sold and
securitized on which it has retained servicing or has provided recourse or other credit
enhancements. This past due information, and trends in the past due amounts, are critical to the
agencies’ ability to evaluate the credit quality of the underlying assets in securitization structures
on an off-site basis and timely identify any credit quality deterioration for supervisory follow-up,
including, if applicable, the effect of increased servicing costs on current and forecasted
earnings. Defaulting assets underlying securitization structures played a major role during the
recent financial crisis, so it is imperative the agencies have the information necessary to
continuously monitor the performance of these assets.
The agencies also use Schedule RC-S data to analyze whether an institution has adequate
capital to cover losses arising from liquidity commitments or recourse obligations if the
underlying assets in securitizations begin to default, especially in the event of an economic
downturn. In addition, on an industry-wide basis, changes in the level of activity reported in the
various items of this schedule enables the agencies to identify emerging trends within the
securitization sector, which supports the development, as needed, of supervisory policies and
related guidance for institutions and examiners.
Schedule RC-S is also used by the agencies to prepare for on-site examinations.
Specifically, the level of activity reported in Schedule RC-S helps the agencies make
examination resource decisions, such as whether capital markets or consumer compliance
specialists are needed on-site. (Consumer compliance regulations apply to loans an institution
continues to service after sale or securitization.) For example, in the event there are increasing
amounts of past due loans that an institution has sold and securitized, additional resources can be
allocated to examining the institution’s lending policies and practices and internal controls.
Schedule RC-T (Fiduciary and Related Services)
Schedule RC-T collects data on fiduciary assets and accounts, income generated from
those accounts and other fiduciary services, and related fiduciary activities. The amount of data
reported in Schedule RC-T and the frequency of reporting varies depending on an institution’s
total fiduciary assets and its fiduciary income. The most detail, including income information, is
provided quarterly by institutions that have more than $250 million in fiduciary assets or meet a
fiduciary income test; other trust institutions report less information in Schedule RC-T annually

34

as of December 31.
Trust services are an integral part of the banking business for more than 20 percent of all
institutions. The granularity of the data in Schedule RC-T, especially for the types of managed
assets held in fiduciary accounts, aids the agencies in determining the complexity of an
institution’s fiduciary services risk profile. Furthermore, the agencies use Schedule RC-T data to
monitor changes in the volume and character of discretionary trust activity and the volume of
nondiscretionary trust activity at a trust institution, which facilitates their assessment of the
nature and risks of the institution’s fiduciary activities. The institution’s risk profile in these
areas is considered during pre-examination planning to determine the appropriate scoping and
staffing for trust examinations.
The Schedule RC-T data also are used when examiners consider the ratings to be
assigned to trust institutions under the Uniform Interagency Trust Rating System (UITRS). The
UITRS considers certain managerial, operational, financial, and compliance factors that are
common to all institutions with fiduciary activities. Under this system, the supervisory agencies
endeavor to ensure that all institutions with fiduciary activities are evaluated in a comprehensive
and uniform manner, and that supervisory attention is appropriately focused on those institutions
exhibiting weaknesses in their fiduciary operations.
Schedule RC-T provides a breakdown of the amount and number of managed and nonmanaged accounts by the types of different trust accounts. Personal trusts, employee benefit
trusts, and corporate trusts are reported separately because of their substantive differences in
nature and risk. Having a detailed breakdown between managed and non-managed accounts is
critical because managed accounts have greater levels of investment, legal, reputational, and
compliance risks compared to non-managed accounts, and require more supervisory
oversight. This account information supports examination scoping and staffing because the
evaluation of different types of trust accounts requires differences in expertise.
Data reported by larger trust institutions on fiduciary and related services income and on
fiduciary settlements, surcharges, and other losses provide information on the overall
profitability of the institution’s fiduciary activities and supports the assessment of the Earnings
component of the UITRS rating. These assessments consider such factors as the profitability of
fiduciary activities in relation to the size and scope of the institution’s trust product lines and its
overall trust business. In addition, fiduciary settlements, surcharges, and other losses signal
mishandling, operational failure, or fraud, which pose higher than normal risk exposure to the
institution and raise questions for supervisory follow-up about the effectiveness of the
institution’s controls over its fiduciary activities. These data also are monitored off-site and used
to make interim rating changes in the UITRS Earnings rating between scheduled examinations.
Data in the Schedule RC-T Memorandum items include the market values of managed
assets held in fiduciary accounts by type of account and asset class and the number of collective
investment funds and common trust funds and the market value of fund assets by type of fund.
The exercise of investment discretion adds a significant element of risk to the administration of
managed fiduciary accounts. The breakdowns by asset class and type of fund enable the
agencies to monitor trends, both on a trust industry-wide basis and an individual trust institution

35

basis, in how institutions with investment discretion are investing the assets of managed accounts
and investment funds. The market value breakdowns of managed assets by asset class provide
an indicator of complexity by separating more complex and hard-to-value assets that carry higher
levels of risk from those assets that pose less risk. These data also contribute to effective
examination scoping and staffing so that trust examiners can be assigned, and their time
allocated, to examining those more complex and higher risk activities in which they have
expertise. For example, the separately reported managed asset classes of real estate mortgages
and real estate are distinctly different asset classes with different risk and return profiles, cash
flows, and liquidity characteristics. Thus, concentrations in either of these asset classes may
inform the supervisory strategy for managed fiduciary accounts, including the level of
specialized expertise that may be required when there are concentrations in these asset classes.
Trust institutions also report the number of corporate and municipal debt issues for which
the institution serves as trustee that are in substantive default and the outstanding principal
amount of these debt issues. A substantive default occurs when the issuer fails to make a
required payment of interest or principal, defaults on a required payment into a sinking fund, or
is declared bankrupt or insolvent. The occurrence of a substantive default significantly raises the
risk profile for the institution serving as an indenture trustee of a defaulted issue and can result in
the incurrence of significant expenses and the distraction of managerial time and attention from
other areas of trust administration. Thus, by monitoring the corporate trust data reported in
Schedule RC-T between examinations, the agencies are able to identify changes in the risk
profile of institutions acting as indenture trustees for timely supervisory follow-up and
appropriate examination scoping and staffing.
The existence of fiduciary activities reported in Schedule RC-T may result in scoping
certain areas of review into a consumer compliance examination, such as privacy and incentivebased cross-selling. The schedule also contains essential information for statistical and
analytical purposes, including calculating the OCC assessments for independent trust banks.
Schedule RC-V (Variable Interest Entities) (FFIEC 031 and FFIEC 041 only)
Schedule RC-V collects information on an institution’s consolidated variable interest
entities (VIEs) as defined by FASB ASC Topic 810, Consolidation. The data are used in
determining the extent to which an institution’s VIEs have been created as securitization vehicles
to pool and repackage mortgages, other assets, or other credit exposures into securities that have
been or can be transferred to investors or for other purposes. Examiners and reviewers can
quantify the level of cash and noninterest-bearing balances, securities, loans, and other assets as
well as liabilities tied to VIEs that are reflected in the amounts reported in the corresponding
asset and liability categories on the parent institution’s consolidated balance sheet. While
securitization activities present many risks, the data on VIEs are particularly useful for
monitoring and examining credit risk or the risk to earnings performance from the VIEs’
activities. Depending on the volume of an institution’s VIEs, VIE assets that can be used only to
settle obligations of the consolidated VIEs can also impact off-site assessments of the parent
institution’s liquidity position given the restrictions on the use of the VIEs’ assets for borrowing
purposes. Thus, the analysis of amounts reported in Schedule RC-V assists with planning the
proper scoping and staffing of examinations of institutions with activities conducted through

36

VIEs.

37

Appendix B
FFIEC 051: To be completed by banks with domestic offices only and total assets less than
$1 billion.
Data Items Removed, Other Impacts to Data Items,
or New or Increased Reporting Threshold
Data Items Removed
Schedule RC-A, Cash and Balances Due from Depository Institutions, removed.
Schedule
RC-B

Item
4.a.(1)

Item Name
Residential mortgage pass-through
securities: Guaranteed by GNMA
(Columns A through D)

RC-B

4.a.(2)

Residential mortgage pass-through
securities: Issued by FNMA and FHLMC
(Columns A through D)

RC-F

3.a

RC-F

3.b

RC-F

6.d

SU

8.e

Note: Items 4.a.(1) and 4.a.(2) of Schedule
RC-B will be combined into one data item
(new item 4.a).
Interest-only strips receivable (not in the
form of a security) on mortgage loans
Interest-only strips receivable (not in the
form of a security) on other financial assets
Note: Items 3.a and 3.b of Schedule RC-F
will be combined into one data item (new
item 3).
Retained interests in accrued interest
receivable related to securitized credit
cards
Outstanding credit card fees and finance
charges included in retail credit card
receivables sold and securitized with
servicing retained or with recourse or other
seller-provided credit enhancements

38

MDRM Number
RCONG300,
RCONG301,
RCONG302,
RCONG303
RCONG304,
RCONG305,
RCONG306,
RCONG307

RCONA519

RCONA520

RCONC436

RCONC407

Other Impacts to Data Items
Schedule
RC-B

RC-F

Item
4.a.(1)
(New)

3 (New)

Item Name
Residential mortgage pass-through
securities: Issued or guaranteed by FNMA,
FHLMC, or GNMA (Columns A through
D)
Note: Items 4.a.(1) and 4.a.(2) of Schedule
RC-B will be combined into this data item.
Interest-only strips receivable (not in the
form of a security)

MDRM Number
To be determined
(TBD) – 4 MDRM
Numbers

TBD

Note: Items 3.a and 3.b of Schedule RC-F
removed above will be combined into this
data item.

Data Items with a New or Increased Reporting Threshold
Schedule RC-T: Increase the threshold for the exemption from reporting Schedule RC-T
items 14 through 26, from institutions with fiduciary assets of $100 million or less to
institutions with fiduciary assets of $250 million or less (that do not meet the fiduciary
income test for quarterly reporting).
Schedule Item
RC-T
14
RC-T

15.a

RC-T

15.b

RC-T

15.c

RC-T

16

RC-T

17

RC-T

18

Item Name
Income from personal trust and agency
accounts
Income from employee benefit and
retirement-related trust and agency
accounts: Employee benefit—defined
contribution
Income from employee benefit and
retirement-related trust and agency
accounts: Employee benefit—defined
benefit
Income from employee benefit and
retirement-related trust and agency
accounts: Other employee benefit and
retirement-related accounts
Income from corporate trust and agency
accounts
Income from investment management
and investment advisory agency accounts
Income from foundation and endowment
trust and agency accounts

39

MDRM Number
RIADB904
RIADB905

RIADB906

RIADB907

RIADA479
RIADJ315
RIADJ316

Schedule Item
RC-T
19
RC-T
20
RC-T

21

RC-T

22

RC-T
RC-T

23
24

RC-T

25

RC-T

26

Item Name
Income from other fiduciary accounts
Income from custody and safekeeping
accounts
Other fiduciary and related services
income
Total gross fiduciary and related services
income
Less: Expenses
Less: Net losses from fiduciary and
related services
Plus: Intracompany income credits for
fiduciary and related services
Net fiduciary and related services income

MDRM Number
RIADA480
RIADB909
RIADB910
RIAD4070
RIADC058
RIADA488
RIADB911
RIADA491

To be completed by banks with collective investment funds and common trust funds with a
total market value of $1 billion or more as of the preceding December 31.
Schedule Item
Item Name
MDRM Number
RC-T

M3.a

RC-T

M3.b

RC-T

M3.c

RC-T

M3.d

RC-T

M3.e

RC-T

M3.f

RC-T

M3.g

Collective investment funds and common
trust funds: Domestic equity (Columns A
and B)
Collective investment funds and common
trust funds: International/Global equity
(Columns A and B)
Collective investment funds and common
trust funds: Stock/Bond blend (Columns A
and B)
Collective investment funds and common
trust funds: Taxable bond (Columns A and
B)
Collective investment funds and common
trust funds: Municipal bond (Columns A
and B)
Collective investment funds and common
trust funds: Short-term investments/Money
market (Columns A and B)
Collective investment funds and common
trust funds: Specialty/Other (Columns A
and B)

40

RCONB931,
RCONB932
RCONB933,
RCONB934
RCONB935,
RCONB936
RCONB937,
RCONB938
RCONB939,
RCONB940
RCONB941,
RCONB942
RCONB943,
RCONB944

Appendix C
FFIEC 041: To be completed by banks with domestic offices only and consolidated total
assets less than $100 billion, except those banks that file the FFIEC 051.

Data Items Removed, Other Impacts to Data Items,
or New or Increased Reporting Threshold
Data Items Removed
Schedule Item
RC-A
2.a
RC-A

2.b

RC-A

3.a

RC-A

3.b

RC-F

3.a

RC-F

3.b

RC-F

6.d

RC-N

M5.b.(1)

Item Name
Balances due from U.S. branches
and agencies of foreign banks
Balances due from other commercial
banks in the U.S. and other
depository institutions in the U.S.
Note: Items 2.a and 2.b of Schedule
RC-A will be combined into one
data item (new item 2).
Balances due from foreign branches
of other U.S. banks
Balances due from other banks in
foreign countries and foreign central
banks
Note: Items 3.a and 3.b of Schedule
RC-A will be combined into one
data item (new item 3).
Interest-only strips receivable (not in
the form of a security) on mortgage
loans
Interest-only strips receivable (not in
the form of a security) on other
financial assets

MDRM Number
RCON0083
RCON0085

RCON0073
RCON0074

RCONA519

RCONA520

Note: Items 3.a and 3.b of Schedule
RC-F will be combined into one data
item (new item 3).
Retained interests in accrued interest RCONC436
receivable related to securitized
credit cards
Loans measured at fair value: Fair
RCONF664,
value (Columns A through C)
RCONF665, RCONF666

41

Schedule Item
RC-N
M5.b.(2)

RC-P

1.a

RC-P

1.b

RC-P

1.c.(1)

RC-P

1.c.(2)

RC-P

2.a

RC-P

2.b

RC-P

2.c.(1)

RC-P

2.c.(2)

Item Name
Loans measured at fair value:
Unpaid principal balance (Columns
A through C)
Retail originations during the quarter
of 1–4 family residential mortgage
loans for sale: Closed-end first liens
Retail originations during the quarter
of 1–4 family residential mortgage
loans for sale: Closed-end junior
liens
Retail originations during the quarter
of 1–4 family residential mortgage
loans for sale: Open-end loans
extended under lines of credit:
Total commitment under the lines of
credit
Note: Items 1.a, 1.b, and 1.c.(1) of
Schedule RC-P will be combined
into one data item (new item 1).
Retail originations during the quarter
of 1–4 family residential mortgage
loans for sale: Open-end loans
extended under lines of credit:
Principal amount funded under the
lines of credit
Wholesale originations and
purchases during the quarter of 1–4
family residential mortgage loans
for sale: Closed-end first liens
Wholesale originations and
purchases during the quarter of 1–4
family residential mortgage loans
for sale: Closed-end junior liens
Wholesale originations and
purchases during the quarter of 1–4
family residential mortgage loans
for sale: Open-end loans extended
under lines of credit: Total
commitment under the lines of credit
Note: Items 2.a, 2.b, and 2.c.(1) of
Schedule RC-P will be combined
into one data item (new item 2).
Wholesale originations and

42

MDRM Number
RCONF667,
RCONF668, RCONF669
RCONF066

RCONF067

RCONF670

RCONF671

RCONF068

RCONF069

RCONF672

RCONF673

Schedule Item

RC-P

3.a

RC-P

3.b

RC-P

3.c.(1)

RC-P

3.c.(2)

RC-P

4.a

RC-P

4.b

RC-P

4.c.(1)

RC-P

4.c.(2)

RC-P

5.a

Item Name
purchases during the quarter of 1–4
family residential mortgage loans
for sale: Open-end loans extended
under lines of credit: Principal
amount funded under the lines of
credit
1–4 family residential mortgage
loans sold during the quarter:
Closed-end first liens
1–4 family residential mortgage
loans sold during the quarter:
Closed-end junior liens
1–4 family residential mortgage
loans sold during the quarter: Total
commitment under the lines of credit
Note: Items 3.a, 3.b, and 3.c.(1) of
Schedule RC-P will be combined
into one data item (new item 3).
1–4 family residential mortgage
loans sold during the quarter:
Principal amount funded under the
lines of credit
1–4 family residential mortgage
loans held for sale or trading at
quarter-end: Closed-end first liens
1–4 family residential mortgage
loans held for sale or trading at
quarter-end: Closed-end junior liens
1–4 family residential mortgage
loans held for sale or trading at
quarter-end: Total commitment
under the lines of credit
Note: Items 4.a, 4.b, and 4.c.(1) of
Schedule RC-P will be combined
into one data item (new item 4).
1–4 family residential mortgage
loans held for sale or trading at
quarter-end: Principal amount
funded under the lines of credit
Noninterest income for the quarter
from the sale, securitization, and
servicing of 1–4 family
residential mortgage loans: Closed-

43

MDRM Number

RCONF070

RCONF071

RCONF674

RCONF675

RCONF072

RCONF073

RCONF676

RCONF677

RIADF184

Schedule Item

RC-P

5.b

RC-P

6.a

RC-P

6.b

RC-P

6.c.(1)

RC-P

6.c.(2)

RC-Q

2

RC-Q

9

Item Name
end 1–4 family residential mortgage
loans
Noninterest income for the quarter
from the sale, securitization, and
servicing of 1–4 family
residential mortgage loans: Openend 1–4 family residential mortgage
loans extended under lines of credit

MDRM Number

RIADF560

Note: Items 5.a and 5.b of Schedule
RC-P will be combined into one data
item (new item 5).
Repurchases and indemnifications of RCONF678
1–4 family residential mortgage
loans during the quarter: Closed-end
first liens
Repurchases and indemnifications of RCONF679
1–4 family residential mortgage
loans during the quarter: Closed-end
junior liens
Repurchases and indemnifications of RCONF680
1–4 family residential mortgage
loans during the quarter: Total
commitment under the lines of credit
Note: Items 6.a, 6.b, and 6.c.(1) of
Schedule RC-P will be combined
into one data item (new item 6).
Repurchases and indemnifications of
1–4 family residential mortgage
loans during the quarter: Principal
amount funded under the lines of
credit
Federal funds sold and securities
purchased
under agreements to resell (Columns
A through E)
Note: Item 2 of Schedule RC-Q will
be included in item 6, All other
assets.
Federal funds purchased and
securities sold
under agreements to repurchase
(Columns A through E)
44

RCONF681

RCONG478,
RCONG479,
RCONG480,
RCONG481,
RCONG482

RCONG507,
RCONG508,
RCONG509,
RCONG510,

Schedule Item
RC-Q

11

RC-Q

12

RC-Q

M3.a.(1)

RC-Q

M3.a.(2)

RC-Q

M3.a.(4)

RC-Q

M3.a.(5)

Item Name

MDRM Number
RCONG511
Other borrowed money (Columns A RCONG521,
through E)
RCONG522,
RCONG523,
RCONG524,
RCONG525
Subordinated notes and debentures
RCONG526,
(Columns A through E)
RCONG527,
RCONG528,
Note: Items 9, 11 and 12 of Schedule RCONG529,
RC-Q will be included in item 13,
RCONG530
All other liabilities.
Loans measured at fair value:
RCONF578
Construction, land development, and
other land loans
Loans measured at fair value:
RCONF579
Secured by farmland
Loans measured at fair value:
RCONF583
Secured by multifamily (5 or more)
residential properties
Loans measured at fair value:
RCONF584
Secured by nonfarm nonresidential
properties
Note: Items M3.a.(1), M3.a.(2),
M3.a.(4), and M3.a.(5) of Schedule
RC-Q will be combined into one
data item (new item M3.a.(2)).

RC-Q

RC-Q

RC-Q

M3.a.(3)(a)

Loans measured at fair value:
Revolving, open-end loans secured
by 1–4 family residential properties
and extended under lines of credit
M3.a.(3)(b)(1) Loans measured at fair value:
Closed-end loans secured by 1–4
family residential properties:
Secured by first liens
M3.a.(3)(b)(2) Loans measured at fair value:
Closed-end loans secured by 1–4
family residential properties:
Secured by junior liens
Note: Items M3.a.(3)(a),
M3.a.(3)(b)(1), and M3.a.(3)(b)(2)
of Schedule RC-Q will be combined
45

RCONF580

RCONF581

RCONF582

Schedule Item

RC-Q

M3.c.(1)

RC-Q

M3.c.(2)

RC-Q

M3.c.(3)

RC-Q

M3.c.(4)

RC-Q

M4.a.(1)

RC-Q

M4.a.(2)

RC-Q

M4.a.(4)

RC-Q

M4.a.(5)

Item Name
into one data item (new item
M3.a.(1)).
Loans measured at fair value: Credit
cards
Loans measured at fair value: Other
revolving credit plans
Loans measured at fair value:
Automobile loans
Loans measured at fair value: Other
consumer loans
Note: Items M3.c.(1), M3.c.(2),
M3.c.(3), and M3.c.(4) of Schedule
RC-Q will be combined into one
data item (new item M3.c).
Unpaid principal balance of loans
measured at fair value: Construction,
land development, and other land
loans
Unpaid principal balance of loans
measured at fair value: Secured by
farmland
Unpaid principal balance of loans
measured at fair value: Secured by
multifamily (5 or more) residential
properties
Unpaid principal balance of loans
measured at fair value: Secured by
nonfarm nonresidential properties

MDRM Number

RCONF586
RCONF587
RCONK196
RCONK208

RCONF590

RCONF591

RCONF595

RCONF596

Note: Items M4.a.(1), M4.a.(2),
M4.a.(4), and M4.a(5) of Schedule
RC-Q will be combined into one
data item (new item M4.a.(2)).
RC-Q

RC-Q

M4.a.(3)(a)

Unpaid principal balance of loans
measured at fair value: Revolving,
open-end loans secured by 1–4
family residential properties and
extended under lines of credit
M4.a.(3)(b)(1) Unpaid principal balance of loans
measured at fair value: Closed-end
loans secured by 1–4 family
residential properties: Secured by
first liens

46

RCONF592

RCONF593

Schedule Item
Item Name
RC-Q
M4.a.(3)(b)(2) Unpaid principal balance of loans
measured at fair value: Closed-end
loans secured by 1–4 family
residential properties: Secured by
junior liens

RC-Q

M4.c.(1)

RC-Q

M4.c.(2)

RC-Q

M4.c.(3)

RC-Q

M4.c.(4)

RC-S

1

RC-S

2.a

RC-S

2.b

Note: Items M4.a.(3)(a),
M4.a.(3)(b)(1), and M4.a.(3)(b)(2)
of Schedule RC-Q will be combined
into one data item (new item
M4.a.(1)).
Unpaid principal balance of loans
measured at fair value: Credit cards
Unpaid principal balance of loans
measured at fair value: Other
revolving credit plans
Unpaid principal balance of loans
measured at fair value: Automobile
loans
Unpaid principal balance of loans
measured at fair value: Other
consumer loans
Note: Items M4.c.(1), M4.c.(2),
M4.c.(3), and M4.c.(4) of Schedule
RC-Q will be combined into one
data item (new item M4.c).
Outstanding principal balance of
assets sold and securitized by the
reporting bank with servicing
retained or with recourse or other
seller-provided credit enhancements
(Columns B through F)
Note: Item 1, Columns B through F,
of Schedule RC-S will be included
in item 1, Column G.
Maximum amount of credit exposure
arising from recourse or other sellerprovided credit enhancements
provided to structures reported in
item 1 in the form of: Creditenhancing interest-only strips
(Columns A through G)
Maximum amount of credit exposure

47

MDRM Number
RCONF594

RCONF598
RCONF599

RCONK195

RCONK209

RCONB706,
RCONB707,
RCONB708,
RCONB709,
RCONB710

RCONB712,
RCONB713,
RCONB714,
RCONB715,
RCONB716,
RCONB717,
RCONB718
RCONC393,

Schedule Item

RC-S

2.c

RC-S

3

RC-S

4.a

RC-S

RC-S

4.b

5.a

Item Name
arising from recourse or other sellerprovided credit enhancements
provided to structures reported in
item 1 in the form of: Subordinated
securities and other residual interests
(Columns A through G)
Maximum amount of credit exposure
arising from recourse or other sellerprovided credit enhancements
provided to structures reported in
item 1 in the form of: Standby letters
of credit and other enhancements
(Columns A through G)
Note: Items 2.a, 2.b, and 2.c,
Columns A and G, of Schedule RCS will be combined into one data
item (new item 2) for Columns A
and G.
Reporting bank’s unused
commitments to provide liquidity to
structures reported
in item 1 (Columns A through G)

Past due loan amounts included in
item 1: 30–89 days past due
(Columns B through F)
Note: Item 4.a, Columns B through
F, of Schedule RC-S will be
included in item 4.a, Column G.
Past due loan amounts included in
item 1: 90 days or more past due
(Columns B through F)
Note: Item 4.b, Columns B through
F, of Schedule RC-S will be
included in item 4.b, Column G.
Charge-offs and recoveries on assets
sold and securitized with servicing
retained or with recourse or other
seller-provided credit enhancements:
Charge-offs (Columns B through F)

48

MDRM Number
RCONC394,
RCONC395,
RCONC396,
RCONC397,
RCONC398,
RCONC399
RCONC400,
RCONC401,
RCONC402,
RCONC403,
RCONC404,
RCONC405,
RCONC406

RCONB726,
RCONB727,
RCONB728,
RCONB729,
RCONB730,
RCONB731,
RCONB732
RCONB734,
RCONB735,
RCONB736,
RCONB737,
RCONB738

RCONB741,
RCONB742,
RCONB743,
RCONB744,
RCONB745

RIADB748, RIADB749,
RIADB750, RIADB751,
RIADB752

Schedule Item

RC-S

5.b

RC-S

6.a

RC-S

6.b

RC-S

7.a

RC-S

7.b

RC-S

8.a

RC-S

8.b

RC-S

9

Item Name

MDRM Number

Note: Item 5.a, Columns B through
F, of Schedule RC-S will be
included in item 5.a, Column G.
Charge-offs and recoveries on assets
sold and securitized with servicing
retained or with recourse or other
seller-provided credit enhancements:
Recoveries (Columns B through F)
Note: Item 5.b, Columns B through
F, of Schedule RC-S will be
included in item 5.b, Column G.
Amount of ownership (or seller’s)
interests carried as: Securities
(Columns B, C, and F)
Amount of ownership (or seller’s)
interests carried as: Loans (Columns
B, C, and F)
Note: Items 6.a and 6.b, Columns B,
C, and F, of Schedule RC-S will be
combined into one data item (new
item 6) for Column G.
Past due loan amounts included in
interests reported in item 6.a: 30–89
days past due (Columns B, C, and F)
Past due loan amounts included in
interests reported in item 6.a: 90
days or more past due (Columns B,
C, and F)
Charge-offs and recoveries on loan
amounts included in interests
reported in item 6.a: 30–89 days past
due (Columns B, C, and F)
Charge-offs and recoveries on loan
amounts included in interests
reported in item 6.a: 90 days or more
past due (Columns B, C, and F)
Maximum amount of credit exposure
arising from credit enhancements
provided by the reporting bank to
other institutions’ securitization
structures in the form of standby
letters of credit, purchased

49

RIADB755, RIADB756,
RIADB757, RIADB758,
RIADB759

RCONB761,
RCONB762,
RCONB763
RCONB500,
RCONB501,
RCONB502

RCONB764,
RCONB765,
RCONB766
RCONB767,
RCONB768,
RCONB769
RIADB770, RIADB771,
RIADB772

RIADB773, RIADB774,
RIADB775

RCONB777,
RCONB778,
RCONB779,
RCONB780,
RCONB781

Schedule Item

RC-S

RC-S

RC-S

RC-S

RC-S

10

11

12

M1.a

M1.b

Item Name
subordinated securities, and other
enhancements (Columns B through
F)
Note: Item 9, Columns B through F,
of Schedule RC-S will be included
in item 9, Column G.
Reporting bank’s unused
commitments to provide liquidity to
other institutions’
securitization structures (Columns B
through F)
Note: Item 10, Columns B through
F, of Schedule RC-S will be
included in item 10, Column G.
Assets sold with recourse or other
seller-provided credit enhancements
and not securitized by the reporting
bank (Columns B through F)
Note: Item 11, Columns B through
F, of Schedule RC-S will be
included in item 11, Column G.
Maximum amount of credit exposure
arising from recourse or other sellerprovided credit enhancements
provided to assets reported in item
11 (Columns B through F)
Note: Item 12, Columns B through
F, of Schedule RC-S will be
included in item 12, Column G.
Small business obligations
transferred with recourse under
Section 208 of the Riegle
Community Development and
Regulatory Improvement Act of
1994: Outstanding principal balance

MDRM Number

RCONB784,
RCONB785,
RCONB786,
RCONB787,
RCONB788

RCONB791,
RCONB792,
RCONB793,
RCONB794,
RCONB795

RCONB798,
RCONB799,
RCONB800,
RCONB801,
RCONB802

RCONA249

Note: Item M.l.a of Schedule RC-S
will be included in item 1 or item 11,
Column G, as appropriate.
Small business obligations
RCONA250
transferred with recourse under

50

Schedule Item

RC-V

All data items
reported for
“ABCP
Conduits”
(Column B)

RC-V

1.b

RC-V

1.c

RC-V

1.d

Item Name
Section 208 of the Riegle
Community Development and
Regulatory Improvement Act of
1994: Amount of retained recourse
on these obligations as of the report
date
Note: Item M.1.b of Schedule RC-S
will be included in item 2 or 12,
Column G, as appropriate.
ABCP Conduits (Column B)
Note: Data items currently reported
for “ABCP Conduits” (Column B)
will be included in the “Other VIEs”
column (Column C, to be relabeled
as Column B) of Schedule RC-V by
line item, as reflected below.

Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Held-to-maturity
securities (Columns A and C)
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Available-forsale securities (Columns A and C)
Note: Items 1.b and 1.c, Columns A
and C, of Schedule RC-V will be
combined into one data item (new
item 1.b) for Columns A and C (the
latter to be relabeled as Column B).
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the

51

MDRM Number

RCONJ982,
RCONJ985, RCONJ988,
RCONJ991 RCONJ994,
RCONJ997,
RCONK001,
RCONK004,
RCONK007,
RCONK010,
RCONK013,
RCONK016,
RCONK019,
RCONK022
RCONK025,
RCONK028
RCONK031,
RCONK034
RCONJ984, RCONJ986

RCONJ987, RCONJ989

RCONJ990, RCONJ992

Schedule Item

RC-V

1.e

RC-V

1.f

RC-V

1.g

RC-V

1.h

Item Name
MDRM Number
consolidated VIEs: Securities
purchased under agreements to resell
(Columns A and C)
Note: Item 1.d, Columns A and C, of
Schedule RC-V will be included in
item 1.k, Other assets (renumbered
as item 1.e), for Columns A and C
(the latter to be relabeled as Column
B).
Assets of consolidated variable
RCONJ993, RCONJ995
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Loans and leases
held for sale (Columns A and C)
Assets of consolidated variable
RCONJ996, RCONJ998
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Loans and leases
held for investment (Columns A and
C)
Assets of consolidated variable
RCONJ999, RCONK002
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Less: Allowance
for loan and lease losses (Columns A
and C)
Note: Items 1.e, 1.f, and 1.g,
Columns A and C, of Schedule RCV will be combined into one data
item (new item 1.c) for Columns A
and C (the latter to be relabeled as
Column B).
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Trading assets
(other than derivatives) (Columns A
and C)
Note: Item 1.h, Columns A and C, of
Schedule RC-V will be included in
item 1.k, Other assets (renumbered
as item 1.e), for Columns A and C

52

RCONK003,
RCONK005

Schedule Item

RC-V

RC-V

RC-V

RC-V

1.i

2.a

2.b

2.c

Item Name
(the latter to be relabeled as Column
B).
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Derivative
trading assets (Columns A and C)
Note: Item 1.i, Columns A and C, of
Schedule RC-V will be included in
item 1.k, Other assets (renumbered
as item 1.e), for Columns A and C
(the latter to be relabeled as Column
B).
Liabilities of consolidated VIEs for
which creditors do not have recourse
to the general credit of the reporting
bank: Securities sold under
agreements to repurchase (Columns
A and C)
Note: Item 2.a, Columns A and C, of
Schedule RC-V will be included in
item 2.e, Other liabilities
(renumbered as item 2.b), for
Columns A and C (the latter to be
relabeled as Column B).
Liabilities of consolidated VIEs for
which creditors do not have recourse
to the general credit of the reporting
bank: Derivative trading liabilities
(Columns A and C)

MDRM Number

RCONK006,
RCONK008

RCONK015,
RCONK017

RCONK018,
RCONK020

Note: Item 2.b, Columns A and C, of
Schedule RC-V will be included in
item 2.e, Other liabilities
(renumbered as item 2.b), for
Columns A and C (the latter to be
relabeled as Column B).
Liabilities of consolidated VIEs for
RCONK021,
which creditors do not have recourse RCONK023
to the general credit of the reporting
bank: Commercial paper (Columns
A and C)

53

Schedule Item

Item Name
Note: Item 2.c, Columns A and C, of
Schedule RC-V will be included in
item 2.d, Other borrowed money
(renumbered as item 2.a), for
Columns A and C (the latter to be
relabeled as Column B).

MDRM Number

Other Impacts to Data Items
Schedule Item
RC-A
2 (New)

RC-A

RC-F

RC-P

RC-P

RC-P

3 (New)

3 (New)

Item Name
Balances due from depository
institutions in the U.S.
Note: Items 2.a. and 2.b of Schedule
RC-A will be combined into this data
item.
Balances due from banks in foreign
countries and foreign central banks
Note: Items 3.a. and 3.b of Schedule
RC-A will be combined into this data
item.
Interest-only strips receivable (not in the
form of a security)

MDRM Number
RCON0082

RCON0070

To be determined
(TBD)

1 (New)

Note: Items 3.a and 3.b of Schedule RCF will be combined into this data item.
Retail originations during the quarter of
1–4 family residential mortgage loans
for sale

TBD

2 (New)

Note: Items 1.a, 1.b, and 1.c.(1) of
Schedule RC-P will be combined into
this data item.
Wholesale originations and purchases
during the quarter of 1–4 family
residential mortgage loans
for sale

TBD

3 (New)

Note: Items 2.a, 2.b, and 2.c.(1) of
Schedule RC-P will be combined into
this data item.
1–4 family residential mortgage loans
sold during the quarter

54

TBD

Schedule Item

RC-P

RC-P

RC-P

RC-Q

RC-Q

RC-Q

RC-Q

4 (New)

Item Name

MDRM Number

Note: Items 3.a, 3.b, and 3.c.(1) of
Schedule RC-P will be combined into
this data item.
1–4 family residential mortgage loans
held for sale or trading at quarter-end

TBD

5 (New)

Note: Items 4.a, 4.b, and 4.c.(1) of
Schedule RC-P will be combined into
this data item.
Noninterest income for the quarter from
the sale, securitization, and servicing of
1–4 family
residential mortgage loans

TBD

6 (New)

Note: Items 5.a and 5.b of Schedule RCP will be combined into this data item.
Repurchases and indemnifications of 1–
4 family residential mortgage loans
during the quarter

TBD

M3.a.(1)
(New)

Note: Items 6.a, 6.b, and 6.c.(1) of
Schedule RC-P will be combined into
this data item.
Loans measured at fair value: Secured
by 1–4 family residential properties

M3.a.(2)
(New)

Note: Items M3.a.(3)(a), M3.a.(3)(b)(1),
and M3.a.(3)(b)(1) of Schedule RC-Q
will be combined into this data item.
Loans measured at fair value: All other
TBD
loans secured by real estate

M3.c
(New)

M4.a.(1)
(New)

Note: Items M3.a.(1), M3.a.(2),
M3.a.(4), and M3.a.(5) of Schedule RCQ will be combined into this data item.
Loans measured at fair value: Loans to
individuals for household, family, and
other personal expenditures
Note: Items M3.c.(1), M3.c.(2),
M3.c.(3), and M3.c.(4) of Schedule RCQ will be combined into this data item.
Unpaid principal balance of loans
measured at fair value: Secured by 1–4

55

TBD

TBD

TBD

Schedule Item

RC-Q

RC-Q

RC-S

RC-S

RC-V

M4.a.(2)
(New)

M4.c
(New)

2 (New)

6 (New)

1.b (New)

Item Name
family residential properties
Note: Items M4.a.(3)(a), M4.a.(3)(b)(1),
and M4.a.(3)(b)(2) of Schedule RC-Q
will be combined into this data item.
Unpaid principal balance of loans
measured at fair value: All other loans
secured by real estate

MDRM Number

TBD

Note: Items M4.a.(1), M4.a.(2),
M4.a.(4), and M4.a.(5) of Schedule RCQ will be combined into this data item.
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family, and
other personal expenditures

TBD

Note: Items M4.c.(1), M4.c.(2),
M4.c.(3), and M4.c.(4) of Schedule RCQ will be combined into this data item.
Maximum amount of credit exposure
arising from recourse or other sellerprovided credit enhancements provided
to structures reported in item 1
(Columns A and G)

TBD (2 MDRM
numbers)

Note: Items 2.a, 2.b, and 2.c, Columns A
and G, of Schedule RC-S will be
combined into this data item.
Total amount of ownership (or seller’s)
TBD (3 MDRM
interest carried as securities or loans
Numbers)
(Columns B, C, and F)
Note: Items 6.a and 6.b, Columns B, C,
and F, of Schedule RC-S will be
combined into this data item for Column
G.
Assets of consolidated variable interest
entities (VIEs) that can be used only to
settle
obligations of the consolidated VIEs:
Securities (Columns A and C)
Note: Items 1.b and 1.c, Columns A and
C, of Schedule RC-V removed above

56

TBD (2 MDRM
Numbers)

Schedule Item

RC-V

1.c (New)

RC-V

5 (New)

RC-V

6 (New)

Item Name
will be combined into this data item for
Columns A and C (the latter to be
relabeled as Column B).
Assets of consolidated variable interest
entities (VIEs) that can be used only to
settle
obligations of the consolidated VIEs:
Loans and leases held for investment,
net of allowance, and held for sale
(Columns A and C)
Note: Items 1.e, 1.f, and 1.g, Columns A
and C, of Schedule RC-V removed
above will be combined into this data
item for Columns A and C (the latter to
be relabeled as Column B).
Total assets of asset-backed commercial
paper (ABCP) conduit VIEs
Total liabilities of ABCP conduit VIEs

MDRM Number

TBD (2 MDRM
Numbers)

TBD
TBD

Data Items with a New or Increased Reporting Threshold
Schedule RC-P is to be completed by institutions where any of the following residential
mortgage banking activities exceeds $10 million for two consecutive quarters:
 1-4 family residential mortgage loan originations and purchases for resale from all
sources during a calendar quarter; or
 1-4 family residential mortgage loan sales during a calendar quarter; or
 1-4 family residential mortgage loans held for sale or trading at calendar quarter-end.
Schedule RC-Q is to be completed by banks that: (1) have elected to report financial
instruments or servicing assets and liabilities at fair value under a fair value option with
changes in fair value recognized in earnings, or (2) are required to complete Schedule RCD, Trading Assets and Liabilities.
Schedule RC-T: Increase the threshold for the exemption from reporting Schedule RC-T,
data items 14 through 26, from institutions with fiduciary assets of $100 million or less to
institutions with fiduciary assets of $250 million or less (that do not meet the fiduciary
income test for quarterly reporting).
Schedule Item
RC-T
14
RC-T

15.a

Item Name
Income from personal trust and agency
accounts
Income from employee benefit and
retirement-related trust and agency
57

MDRM Number
RIADB904
RIADB905

Schedule Item

RC-T

15.b

RC-T

15.c

RC-T

16

RC-T

17

RC-T

18

RC-T
RC-T

19
20

RC-T

21

RC-T

22

RC-T
RC-T

23
24

RC-T

25

RC-T

26

Item Name
accounts: Employee benefit—defined
contribution
Income from employee benefit and
retirement-related trust and agency
accounts: Employee benefit—defined
benefit
Income from employee benefit and
retirement-related trust and agency
accounts: Other employee benefit and
retirement-related accounts
Income from corporate trust and agency
accounts
Income from investment management
and investment advisory agency
accounts
Income from foundation and
endowment trust and agency accounts
Income from other fiduciary accounts
Income from custody and safekeeping
accounts
Other fiduciary and related services
income
Total gross fiduciary and related
services income
Less: Expenses
Less: Net losses from fiduciary and
related services
Plus: Intracompany income credits for
fiduciary and related services
Net fiduciary and related services
income

MDRM Number

RIADB906

RIADB907

RIADA479
RIADJ315

RIADJ316
RIADA480
RIADB909
RIADB910
RIAD4070
RIADC058
RIADA488
RIADB911
RIADA491

To be completed by banks with collective investment funds and common trust funds with a
total market value of $1 billion or more as of the preceding December 31.
Schedule Item
Item Name
MDRM Number
RC-T

M3.a

RC-T

M3.b

Collective investment funds and common
trust funds: Domestic equity (Columns A
and B)
Collective investment funds and common
trust funds: International/Global equity
(Columns A and B)

58

RCONB931,
RCONB932
RCONB933,
RCONB934

RC-T

M3.c

RC-T

M3.d

RC-T

M3.e

RC-T

M3.f

RC-T

M3.g

Collective investment funds and common
trust funds: Stock/Bond blend (Columns A
and B)
Collective investment funds and common
trust funds: Taxable bond (Columns A and
B)
Collective investment funds and common
trust funds: Municipal bond (Columns A
and B)
Collective investment funds and common
trust funds: Short-term investments/Money
market (Columns A and B)
Collective investment funds and common
trust funds: Specialty/Other (Columns A
and B)

To be completed by banks with $10 billion or more in total assets.
Schedule Item
Item Name
RC-S
6 (New)
Total amount of ownership (or seller’s)
interest carried as securities or loans
(Column G)
RC-S
10
Reporting bank’s unused commitments
to provide liquidity to other institutions’
securitization structures (Columns A and
G)
RC-S
M3.a.(1)
Asset-backed commercial paper
conduits: Maximum amount of credit
exposure arising from credit
enhancements provided to conduit
structures in the form of standby letters
of credit, subordinated securities, and
other enhancements: Conduits sponsored
by the bank, a bank affiliate, or the
bank’s holding company
RC-S
M3.a.(2)
Asset-backed commercial paper
conduits: Maximum amount of credit
exposure arising from credit
enhancements provided to conduit
structures in the form of standby letters
of credit, subordinated securities, and
other enhancements: Conduits sponsored
by other unrelated institutions
RC-S
M3.b.(1)
Asset-backed commercial paper
conduits: Unused commitments to
provide liquidity to conduit structures:

59

RCONB935,
RCONB936
RCONB937,
RCONB938
RCONB939,
RCONB940
RCONB941,
RCONB942
RCONB943,
RCONB944

MDRM Number
TBD

RCONB783,
RCONB789

RCONB806

RCONB807

RCONB808

Schedule Item

RC-S

M3.b.(2)

RC-S

M4

Item Name
Conduits sponsored by the bank, a bank
affiliate, or the bank’s holding company
Asset-backed commercial paper
conduits: Unused commitments to
provide liquidity to conduit structures:
Conduits sponsored by other unrelated
institutions
Outstanding credit card fees and finance
charges included in Schedule RC-S,
item 1, column C
Note: With the combining of Columns B
through F of item 1 of Schedule RC-S
into item 1, Column G, of Schedule RCS, the reference to column C in the
caption for M4 will be changed to
column G.

60

MDRM Number

RCONB809

RCONC407

Appendix D
FFIEC 031: To be completed by banks with domestic and foreign offices and banks with
domestic offices only and consolidated total assets of $100 billion or more.

Data Items Removed, Other Impacts to Data Items,
or New or Increased Reporting Threshold
Data Items Removed
Schedule Item
RC-A
2.a
RC-A

2.b

RC-A

3.a

RC-A

3.b

RC-F

3.a

RC-F

3.b

RC-F

6.d

Item Name
Balances due from U.S. branches and
agencies of foreign banks (Column A)
Balances due from other commercial
banks in the U.S. and other depository
institutions in the U.S. (Column A)
Note: Items 2.a and 2.b (Column A),
of Schedule RC-A will be combined
into one data item (new item 2).
Balances due from foreign branches
of other U.S. banks (Column A)
Balances due from other banks in
foreign countries and foreign central
banks (Column A)
Note: Items 3.a and 3.b (Column A),
of Schedule RC-A will be combined
into one data item (new item 3).
Interest-only strips receivable (not in
the form of a security) on mortgage
loans
Interest-only strips receivable (not in
the form of a security) on other
financial assets
Note: Items 3.a and 3.b of Schedule
RC-F will be combined into one data
item (new item 3).
Retained interests in accrued interest
receivable related to securitized credit
cards

61

MDRM Number
RCFD0083
RCFD0085

RCFD0073

RCFD0074

RCFDA519

RCFDA520

RCFDC436

Schedule Item
RC-N
M5.b.(1)

RC-N

M5.b.(2)

RC-P

1.a

RC-P

1.b

RC-P

1.c.(1)

RC-P

1.c.(2)

RC-P

2.a

RC-P

2.b

RC-P

2.c.(1)

Item Name
Loans measured at fair value: Fair
value (Columns A through C)

MDRM Number
RCFDF664,
RCFDF665,
RCFDF666
Loans measured at fair value: Unpaid RCFDF667,
principal balance (Columns A through RCFDF668,
C)
RCFDF669
Retail originations during the quarter
RCONF066
of 1–4 family residential mortgage
loans for sale: Closed-end first liens
Retail originations during the quarter
RCONF067
of 1–4 family residential mortgage
loans for sale: Closed-end junior liens
Retail originations during the quarter
RCONF670
of 1–4 family residential mortgage
loans for sale: Open-end loans
extended under lines of credit:
Total commitment under the lines of
credit
Note: Items 1.a, 1.b, and 1.c.(1) of
Schedule RC-P will be combined into
one data item (new item 1).
Retail originations during the quarter
of 1–4 family residential mortgage
loans for sale: Open-end loans
extended under lines of credit:
Principal amount funded under the
lines of credit
Wholesale originations and purchases
during the quarter of 1–4 family
residential mortgage loans
for sale: Closed-end first liens
Wholesale originations and purchases
during the quarter of 1–4 family
residential mortgage loans
for sale: Closed-end junior liens
Wholesale originations and purchases
during the quarter of 1–4 family
residential mortgage loans
for sale: Open-end loans extended
under lines of credit: Total
commitment under the lines of credit
Note: Items 2.a, 2.b, and 2.c.(1) of
Schedule RC-P will be combined into

62

RCONF671

RCONF068

RCONF069

RCONF672

Schedule Item
RC-P

2.c.(2)

RC-P

3.a

RC-P

3.b

RC-P

3.c.(1)

RC-P

3.c.(2)

RC-P

4.a

RC-P

4.b

RC-P

4.c.(1)

RC-P

4.c.(2)

RC-P

5.a

Item Name
one data item (new item 2).
Wholesale originations and purchases
during the quarter of 1–4 family
residential mortgage loans
for sale: Open-end loans extended
under lines of credit: Principal amount
funded under the lines of credit
1–4 family residential mortgage loans
sold during the quarter: Closed-end
first liens
1–4 family residential mortgage loans
sold during the quarter: Closed-end
junior liens
1–4 family residential mortgage loans
sold during the quarter: Total
commitment under the lines of credit
Note: Items 3.a, 3.b, and 3.c.(1) of
Schedule RC-P will be combined into
one data item (new item 3).
1–4 family residential mortgage loans
sold during the quarter: Principal
amount funded under the lines of
credit
1–4 family residential mortgage loans
held for sale or trading at quarter-end:
Closed-end first liens
1–4 family residential mortgage loans
held for sale or trading at quarter-end:
Closed-end junior liens
1–4 family residential mortgage loans
held for sale or trading at quarter-end:
Total commitment under the lines of
credit
Note: Items 4.a, 4.b, and 4.c.(1) of
Schedule RC-P will be combined into
one data item (new item 4).
1–4 family residential mortgage loans
held for sale or trading at quarter-end:
Principal amount funded under the
lines of credit
Noninterest income for the quarter
from the sale, securitization, and
servicing of 1–4 family
63

MDRM Number
RCONF673

RCONF070

RCONF071

RCONF674

RCONF675

RCONF072

RCONF073

RCONF676

RCONF677

RIADF184

Schedule Item

RC-P

5.b

RC-P

6.a

RC-P

6.b

RC-P

6.c.(1)

RC-P

6.c.(2)

RC-Q

M3.a

RC-Q

M3.a.(1)

RC-Q

M3.a.(2)

RC-Q

M3.a.(4)

RC-Q

M3.a.(5)

Item Name
residential mortgage loans: Closedend 1–4 family residential mortgage
loans
Noninterest income for the quarter
from the sale, securitization, and
servicing of 1–4 family
residential mortgage loans: Open-end
1–4 family residential mortgage loans
extended under lines of credit
Note: Items 5.a and 5.b of Schedule
RC-P will be combined into one data
item (new item 5).
Repurchases and indemnifications of
1–4 family residential mortgage loans
during the quarter: Closed-end first
liens
Repurchases and indemnifications of
1–4 family residential mortgage loans
during the quarter: Closed-end junior
liens
Repurchases and indemnifications of
1–4 family residential mortgage loans
during the quarter: Total commitment
under the lines of credit
Note: Items 6.a, 6.b, and 6.c.(1) of
Schedule RC-P will be combined into
one data item (new item 6).
Repurchases and indemnifications of
1–4 family residential mortgage loans
during the quarter: Principal amount
funded under the lines of credit
Loans measured at fair value: Loans
secured by real estate (Column A)
Loans measured at fair value:
Construction, land development, and
other land loans (Column B)
Loans measured at fair value: Secured
by farmland (Column B)
Loans measured at fair value: Secured
by multifamily (5 or more) residential
properties (Column B)
Loans measured at fair value: Secured
by nonfarm nonresidential properties

64

MDRM Number

RIADF560

RCONF678

RCONF679

RCONF680

RCONF681

RCFDF608
RCONF578

RCONF579
RCONF583

RCONF584

Schedule Item

Item Name
(Column B)

MDRM Number

Note: Items M3.a.(1), M3.a.(2),
M3.a.(4), and M3.a.(5), Column B, of
Schedule RC-Q will be combined into
one data item for the consolidated
bank (new item M3.a.(2), Column A).
RC-Q

RC-Q

RC-Q

M3.a.(3)(a)

Loans measured at fair value:
Revolving, open-end loans secured by
1–4 family residential properties and
extended under lines of credit
(Column B)
M3.a.(3)(b)(1) Loans measured at fair value: Closedend loans secured by 1–4 family
residential properties: Secured by first
liens (Column B)
M3.a.(3)(b)(2) Loans measured at fair value: Closedend loans secured by 1–4 family
residential properties: Secured by
junior liens (Column B)

RC-Q

M3.b

RC-Q

M3.c.(1)

RC-Q

M3.c.(2)

RC-Q

M3.c.(3)

RC-Q

M3.c.(4)

Note: Items M3.a.(3)(a),
M3.a.(3)(b)(1), and M3.a.(3)(b)(2),
Column B, of Schedule RC-Q will be
combined into one data item for the
consolidated bank (new item
M3.a.(1), Column A).
Loans measured at fair value:
Commercial and industrial loans
(Column B)
Loans measured at fair value: Credit
cards (Columns A and B)
Loans measured at fair value: Other
revolving credit plans (Columns A
and B)
Loans measured at fair value:
Automobile loans (Columns A and B)
Loans measured at fair value: Other
consumer loans (Columns A and B)
Note: Items M3.c.(1), M3.c.(2),
M3.c.(3), and M3.c.(4), Column A, of
Schedule RC-Q will be combined into
one data item for the consolidated

65

RCONF580

RCONF581

RCONF582

RCONF585

RCFDF586,
RCONF586
RCFDF587,
RCONF587
RCFDK196,
RCONK196
RCFDK208,
RCONK208

Schedule Item
RC-Q

M3.d

RC-Q

M4.a

RC-Q

M4.a.(1)

RC-Q

M4.a.(2)

RC-Q

M4.a.(4)

RC-Q

M4.a.(5)

RC-Q

RC-Q

RC-Q

Item Name
bank (new item M3.c, Column A).
Loans measured at fair value: Other
loans (Column B)
Unpaid principal balance of loans
measured at fair value: Loans secured
by real estate (Column A)
Unpaid principal balance of loans
measured at fair value: Construction,
land development, and other land
loans (Column B)
Unpaid principal balance of loans
measured at fair value: Secured by
farmland (Column B)
Unpaid principal balance of loans
measured at fair value: Secured by
multifamily (5 or more) residential
properties (Column B)
Unpaid principal balance of loans
measured at fair value: Secured by
nonfarm nonresidential properties
(Column B)

Note: Items M4.a.(1), M4.a.(2),
M4.a.(4), and M4.a.(5), Column B, of
Schedule RC-Q will be combined into
one data item for the consolidated
bank (new item M4.a.(2), Column A).
M4.a.(3)(a)
Unpaid principal balance of loans
measured at fair value: Revolving,
open-end loans secured by 1–4 family
residential properties and extended
under lines of credit (Column B)
M4.a.(3)(b)(1) Unpaid principal balance of loans
measured at fair value: Closed-end
loans secured by 1–4 family
residential properties: Secured by first
liens (Column B)
M4.a.(3)(b)(2) Unpaid principal balance of loans
measured at fair value: Closed-end
loans secured by 1–4 family
residential properties: Secured by
junior liens (Column B)
Note: Items M4.a.(3)(a),
M4.a.(3)(b)(1), and M4.a.(3)(b)(2),
66

MDRM Number
RCONF589
RCFDF609

RCONF590

RCONF591

RCONF595

RCONF596

RCONF592

RCONF593

RCONF594

Schedule Item

RC-Q

M4.b

RC-Q

M4.c.(1)

RC-Q

M4.c.(2)

RC-Q

M4.c.(3)

RC-Q

M4.c.(4)

RC-Q

M4.d

RC-S

2.a

RC-S

2.b

RC-S

2.c

Item Name
Column B, of Schedule RC-Q will be
combined into one data item for the
consolidated bank (new item
M4.a.(1), Column A).
Unpaid principal balance of loans
measured at fair value: Commercial
and industrial loans (Column B)
Unpaid principal balance of loans
measured at fair value: Credit cards
(Columns A and B)
Unpaid principal balance of loans
measured at fair value: Other
revolving credit plans (Columns A
and B)
Unpaid principal balance of loans
measured at fair value: Automobile
loans (Columns A and B)
Unpaid principal balance of loans
measured at fair value: Other
consumer loans (Columns A and B)
Note: Items M4.c.(1), M4.c.(2),
M4.c.(3) and M4.c.(4), Column A, of
Schedule RC-Q will be combined into
one data item for the consolidated
bank (new item M4.c, Column A).
Unpaid principal balance of loans
measured at fair value: Other loans
(Column B)
Maximum amount of credit exposure
arising from recourse or other sellerprovided credit enhancements
provided to structures reported in item
1 in the form of: Credit-enhancing
interest-only strips (Columns A
through G)
Maximum amount of credit exposure
arising from recourse or other sellerprovided credit enhancements
provided to structures reported in item
1 in the form of: Subordinated
securities and other residual interests
(Columns A through G)
Maximum amount of credit exposure
arising from recourse or other seller-

67

MDRM Number

RCONF597

RCFDF598,
RCONF598
RCFDF599,
RCONF599

RCFDK195,
RCONK195
RCFDK209,
RCONK209

RCONF601

RCFDB712,
RCFDB713,
RCFDB714,
RCFDB715,
RCFDB716,
RCFDB717,
RCFDB718
RCFDC393,
RCFDC394,
RCFDC395,
RCFDC396,
RCFDC397,
RCFDC398,
RCFDC399
RCFDC400,
RCFDC401,

Schedule Item

RC-S

6.a

RC-S

6.b

RC-S

7.a

RC-S

7.b

RC-S

8.a

RC-S

8.b

RC-S

9

Item Name
provided credit enhancements
provided to structures reported in item
1 in the form of: Standby letters of
credit and other enhancements
(Columns A through G)

MDRM Number
RCFDC402,
RCFDC403,
RCFDC404,
RCFDC405,
RCFDC406

Note: Items 2.a, 2.b, and 2.c, Columns
A through G, of Schedule RC-S will
be combined into one data item (new
item 2) for Columns A through G.
Amount of ownership (or seller’s)
interests carried as: Securities
(Columns B, C and F)
Amount of ownership (or seller’s)
interests carried as: Loans (Columns
B, C and F)

RCFDB761,
RCFDB762,
RCFDB763
RCFDB500,
RCFDB501,
RCFDB502

Note: Items 6.a and 6.b, Columns B,
C, and F, of Schedule RC-S will be
combined into one data item (new
item 6).
Past due loan amounts included in
interests reported in item 6.a: 30–89
days past due (Columns B, C, and F)
Past due loan amounts included in
interests reported in item 6.a: 90 days
or more past due (Columns B, C, and
F)
Charge-offs and recoveries on loan
amounts included in interests reported
in item 6.a: 30–89 days past due
(Columns B, C, and F)
Charge-offs and recoveries on loan
amounts included in interests reported
in item 6.a: 90 days or more past due
(Columns B, C, and F)
Maximum amount of credit exposure
arising from credit enhancements
provided by the reporting bank to
other institutions’ securitization
structures in the form of standby
letters of credit, purchased
subordinated securities, and other
enhancements (Columns B and C)

68

RCFDB764,
RCFDB765,
RCFDB766
RCFDB767,
RCFDB768,
RCFDB769
RIADB770,
RIADB771,
RIADB772
RIADB773,
RIADB774,
RIADB775
RCFDB777,
RCFDB778

Schedule Item

RC-S

RC-S

RC-S

RC-S

RC-S

10

11

12

M1.a

M1.b

Item Name
Note: Item 9, Columns B and C, of
Schedule RC-S will be included in
item 9, Column G.
Reporting bank’s unused
commitments to provide liquidity to
other institutions’ securitization
structures (Columns B and C)
Note: Item 10, Columns B and C, of
Schedule RC-S will be included in
item 10, Column G.
Assets sold with recourse or other
seller-provided credit enhancements
and not securitized by the reporting
bank (Columns B through F)
Note: Item 11, Columns B through F,
of Schedule RC-S will be included in
item 11, Column G.
Maximum amount of credit exposure
arising from recourse or other sellerprovided credit enhancements
provided to assets reported in item 11
(Columns B through F)
Note: Item 12, Columns B through F,
of Schedule RC-S will be included in
item 12, Column G.
Small business obligations transferred
with recourse under Section 208 of
the Riegle Community Development
and Regulatory Improvement Act of
1994: Outstanding principal balance
Note: Item M1.a of Schedule RC-S
will be included in item 1 or item 11,
Column F, as appropriate.
Small business obligations transferred
with recourse under Section 208 of
the Riegle Community Development
and Regulatory Improvement Act of
1994: Amount of retained recourse on
these obligations as of the report date
Note: Item M1.b of Schedule RC-S

69

MDRM Number

RCFDB784,
RCFDB785

RCFDB791,
RCFDB792,
RCFDB793,
RCFDB794,
RCFDB795

RCFDB798,
RCFDB799,
RCFDB800,
RCFDB801,
RCFDB802

RCFDA249

RCFDA250

Schedule Item

RC-V

All data items
reported for
“ABCP
Conduits”
(Column B)

RC-V

1.b

RC-V

1.c

RC-V

1.d

Item Name
will be included in item 2 or item 12,
Column F, as appropriate.
ABCP Conduits (Column B)
Note: Data items currently reported
for “ABCP Conduits” (Column B)
will be included in the “Other VIEs”
column (Column C, to be relabeled as
Column B) of Schedule RC-V by line
item, as reflected below.

Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Held-to-maturity
securities (Columns A and C)
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Available-for-sale
securities (Columns A and C)
Note: Items 1.b and 1.c, Columns A
and C, of Schedule RC-V will be
combined into one data item (new
item 1.b) for Columns A and C.
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Securities
purchased under agreements to resell
(Columns A and C)
Note: Item 1.d, Columns A and C, of
Schedule RC-V will be included in
item 1.k, Other assets (renumbered as
item 1.b), for Columns A and C (the

70

MDRM Number

RCFDJ982,
RCFDJ985,
RCFDJ988,
RCFDJ991 RCFDJ994,
RCFDJ997,
RCFDK001,
RCFDK004,
RCFDK007,
RCFDK010,
RCFDK013,
RCFDK016,
RCFDK019,
RCFDK022
RCFDK025,
RCFDK028
RCFDK031,
RCFDK034
RCFDJ984,
RCFDJ986

RCFDJ987,
RCFDJ989

RCFDJ990,
RCFDJ992

Schedule Item
RC-V

1.e

RC-V

1.f

RC-V

1.g

RC-V

RC-V

1.h

1.i

Item Name
latter to be relabeled as Column B).
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Loans and leases
held for sale (Column A and C)
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Loans and leases
held for investment (Column A and
C)
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Less: Allowance
for loan and lease losses (Columns A
and C)
Note: Items 1.e, 1.f, and 1.g, Columns
A and C, of Schedule RC-V will be
combined into one data item (new
item 1.c) for Columns A and C (the
latter to be relabeled as Column B).
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Trading assets
(other than derivatives) (Columns A
and C)
Note: Item 1.h, Columns A and C, of
Schedule RC-V will be included in
item 1.k (renumbered as item 1.e),
Other assets, for Columns A and C
(the latter to be relabeled as Column
B).
Assets of consolidated variable
interest entities (VIEs) that can be
used only to settle obligations of the
consolidated VIEs: Derivative trading
assets (Columns A and C)
Note: Item 1.i, Columns A and C, of
Schedule RC-V will be included in

71

MDRM Number
RCFDJ993,
RCFDJ995

RCFDJ996,
RCFDJ998

RCFDJ999,
RCFDK002

RCFDK003,
RCFDK005

RCFDK006,
RCFDK008

Schedule Item

RC-V

RC-V

RC-V

2.a

2.b

2.c

Item Name
item 1.k, Other assets (renumbered as
item 1.e), for Columns A and C (the
latter to be relabeled as Column B).
Liabilities of consolidated VIEs for
which creditors do not have recourse
to the general credit of the reporting
bank: Securities sold under
agreements to repurchase (Columns A
and C)
Note: Item 2.a, Columns A and C, of
Schedule RC-V will be included in
item 2.e, Other liabilities (renumbered
as item 2.b), for Columns A and C
(the latter to be relabeled as Column
B).
Liabilities of consolidated VIEs for
which creditors do not have recourse
to the general credit of the reporting
bank: Derivative trading liabilities
(Columns A and C)
Note: Item 2.b, Columns A and C, of
Schedule RC-V will be included in
item 2.e, Other liabilities (renumbered
as item 2.b), for Columns A and C
(the latter to be relabeled as Column
B).
Liabilities of consolidated VIEs for
which creditors do not have recourse
to the general credit of the reporting
bank: Commercial paper (Columns A
and C)
Note: Item 2.c, Columns A and C, of
Schedule RC-V will be included in
item 2.d, Other borrowed money
(renumbered as item 2.a), for
Columns A and C (the latter to be
relabeled as Column B).

72

MDRM Number

RCFDK015,
RCFDK017

RCFDK018,
RCFDK020

RCFDK021,
RCFDK023

Other Impacts to Data Items
Schedule Item
RC-A
2 (New)

RC-A

RC-F

RC-H

RC-P

RC-P

RC-P

3 (New)

3 (New)

22 (New)

1 (New)

2 (New)

3 (New)

Item Name
Balances due from depository institutions
in the U.S. (Column A)

MDRM Number
RCFD0082

Note: Items 2.a. and 2.b (Column A), of
Schedule RC-A will be combined into this
data item.
Balances due from banks in foreign
RCFD0070
countries and foreign central banks
(Column A)
Note: Items 3.a. and 3.b (Column A), of
Schedule RC-A will be combined into this
data item.
Interest-only strips receivable (not in the
To be determined
form of a security)
(TBD)
Note: Items 3.a and 3.b of Schedule RC-F
will be combined into this data item.
Total amount of fair value option loans
held for investment and held for sale
Note: The proposed threshold change
applicable to Schedule RC-Q applies to
this item.
Retail originations during the quarter of
1–4 family residential mortgage loans for
sale
Note: Items 1.a, 1.b, and 1.c.(1) of
Schedule RC-P will be combined into this
data item.
Wholesale originations and purchases
during the quarter of 1–4 family
residential mortgage loans
for sale
Note: Items 2.a, 2.b, and 2.c.(1) of
Schedule RC-P will be combined into this
data item.
1–4 family residential mortgage loans
sold during the quarter
Note: Items 3.a, 3.b, and 3.c.(1) of

73

TBD

TBD

TBD

TBD

RC-P

RC-P

RC-P

RC-Q

RC-Q

RC-Q

RC-Q

4 (New)

Schedule RC-P will be combined into this
data item.
1–4 family residential mortgage loans
held for sale or trading at quarter-end

TBD

5 (New)

Note: Items 4.a, 4.b, and 4.c.(1) of
Schedule RC-P will be combined into this
data item.
Noninterest income for the quarter from
the sale, securitization, and servicing of
1–4 family
residential mortgage loans

TBD

6 (New)

Note: Items 5.a and 5.b of Schedule RC-P
will be combined into this data item.
Repurchases and indemnifications of 1–4
family residential mortgage loans during
the quarter

TBD

M3.a.(1)
(New)

M3.a.(2)
(New)

M3.c
(New)

M4.a.(1)

Note: Items 6.a, 6.b, and 6.c.(1) of
Schedule RC-P will be combined into this
data item.
Loans measured at fair value: Secured by
1–4 family residential properties (Column
A)

TBD

Note: Items M3.a.(3)(a), M3.a.(3)(b)(1),
and M3.a.(3)(b)(2), Column B, of
Schedule RC-Q will be combined into this
data item for the consolidated bank.
Loans measured at fair value: All other
TBD
loans secured by real estate (Column A)
Note: Items M3.a.(1), M3.a.(2), M3.a.(4),
and M3.a.(5), Column B, of Schedule RCQ will be combined into this data item for
the consolidated bank.
Loans measured at fair value: Loans to
TBD
individuals for household, family, and
other personal expenditures (Column A)
Note: Items M3.c.(1), M3.c.(2), M3.c.(3),
and M3.c.(4), Column A, of Schedule
RC-Q will be combined into this data
item.
Unpaid principal balance of loans

74

TBD

(New)

RC-Q

RC-Q

RC-S

RC-S

RC-V

M4.a.(2)
(New)

M4.c
(New)

2 (New)

6 (New)

1.b (New)

measured at fair value: Secured by 1–4
family residential properties (Column A)
Note: Items M4.a.(3)(a), M4.a.(3)(b)(1),
and M4.a.(3)(b)(2), Column B, of
Schedule RC-Q will be combined into this
data item for the consolidated bank.
Unpaid principal balance of loans
TBD
measured at fair value: All other loans
secured by real estate (Column A)
Note: Items M4.a.(1), M4.a.(2), M4.a.(4),
and M4.a.(5), Column B, of Schedule RCQ will be combined into this data item for
the consolidated bank.
Unpaid principal balance of loans
TBD
measured at fair value: Loans to
individuals for household, family, and
other personal expenditures (Column A)
Note: Items M4.c.(1), M4.c.(2), M4.c.(3),
and M4.c.(4), Column A, of Schedule
RC-Q will be combined into this data
item.
Maximum amount of credit exposure
arising from recourse or other sellerprovided credit enhancements provided to
structures reported in item 1 (Columns A
through G)
Note: Items 2.a, 2.b, and 2.c, Columns A
through G, of Schedule RC-S will be
combined into this data item.
Total amount of ownership (or seller’s)
interest carried as securities or loans
(Columns B, C, and F)
Note: Items 6.a and 6.b, Columns B, C,
and F, of Schedule RC-S will be
combined into this data item.
Assets of consolidated variable interest
entities (VIEs) that can be used only to
settle
obligations of the consolidated VIEs:
Securities (Columns A and C)

75

TBD (7 MDRM
Numbers)

TBD (3 MDRM
Numbers)

TBD (2 MDRM
Numbers)

RC-V

1.c (New)

RC-V

5 (New)

RC-V

6 (New)

Note: Items 1.b and 1.c, Columns A and
C, of Schedule RC-V removed above will
be combined into this data item for
Columns A and C (the latter to be
relabeled as Column B).
Assets of consolidated variable interest
entities (VIEs) that can be used only to
settle
obligations of the consolidated VIEs:
Loans and leases held for investment, net
of allowance, and held for sale (Columns
A and C)
Note: Items 1.e, 1.f, and 1.g, Columns A
and C, of Schedule RC-V removed above
will be combined into this data item for
Columns A and C (the latter to be
relabeled as Column B).
Total assets of asset-backed commercial
paper (ABCP) conduit VIEs
Total liabilities of ABCP conduit VIEs

TBD (2 MDRM
Numbers)

TBD
TBD

Data Items with a New or Increased Reporting Threshold
Schedule RC-P is to be completed by institutions where any of the following residential
mortgage banking activities (in domestic offices) exceeds $10 million for two consecutive
quarters:
 1-4 family residential mortgage loan originations and purchases for resale from all
sources during a calendar quarter; or
 1-4 family residential mortgage loan sales during a calendar quarter; or
 1-4 family residential mortgage loans held for sale or trading at calendar quarter-end.

Schedule RC-Q is to be completed by banks that: (1) have elected to report financial
instruments or servicing assets and liabilities at fair value under a fair value option with
changes in fair value recognized in earnings, or (2) are required to complete Schedule RCD, Trading Assets and Liabilities.

Schedule RC-T: Increase the threshold for the exemption from reporting Schedule RC-T,
data items 14 through 26, from institutions with fiduciary assets of $100 million or less to
institutions with fiduciary assets of $250 million or less (that do not meet the fiduciary
income test for quarterly reporting).

76

Schedule Item
RC-T
14
RC-T

15.a

RC-T

15.b

RC-T

15.c

RC-T

16

RC-T

17

RC-T

18

RC-T
RC-T

19
20

RC-T

21

RC-T

22

RC-T
RC-T

23
24

RC-T

25

RC-T

26

Item Name
Income from personal trust and agency
accounts
Income from employee benefit and
retirement-related trust and agency
accounts: Employee benefit—defined
contribution
Income from employee benefit and
retirement-related trust and agency
accounts: Employee benefit—defined
benefit
Income from employee benefit and
retirement-related trust and agency
accounts: Other employee benefit and
retirement-related accounts
Income from corporate trust and agency
accounts
Income from investment management
and investment advisory agency accounts
Income from foundation and endowment
trust and agency accounts
Income from other fiduciary accounts
Income from custody and safekeeping
accounts
Other fiduciary and related services
income
Total gross fiduciary and related services
income
Less: Expenses
Less: Net losses from fiduciary and
related services
Plus: Intracompany income credits for
fiduciary and related services
Net fiduciary and related services income

MDRM Number
RIADB904
RIADB905

RIADB906

RIADB907

RIADA479
RIADJ315
RIADJ316
RIADA480
RIADB909
RIADB910
RIAD4070
RIADC058
RIADA488
RIADB911
RIADA491

To be completed by banks with collective investment funds and common trust funds with a
total market value of $1 billion or more as of the preceding December 31
Schedule Item
Item Name
MDRM Number
RC-T

M3.a

RC-T

M3.b

Collective investment funds and common
trust funds: Domestic equity (Columns A
and B)
Collective investment funds and common
trust funds: International/Global equity
(Columns A and B)
77

RCFDB931,
RCFDB932
RCFDB933,
RCFDB934

RC-T

M3.c

RC-T

M3.d

RC-T

M3.e

RC-T

M3.f

RC-T

M3.g

Collective investment funds and common
trust funds: Stock/Bond blend (Columns A
and B)
Collective investment funds and common
trust funds: Taxable bond (Columns A and
B)
Collective investment funds and common
trust funds: Municipal bond (Columns A
and B)
Collective investment funds and common
trust funds: Short-term investments/Money
market (Columns A and B)
Collective investment funds and common
trust funds: Specialty/Other (Columns A
and B)

To be completed by banks with $10 billion or more in total assets
Schedule Item
Item Name
RC-S
6 (New)
Total amount of ownership (or seller’s)
interest carried as securities or loans
(Columns B, C, and F)
RC-S
10
Reporting bank’s unused commitments
to provide liquidity to other institutions’
securitization structures (Columns A and
D through G)
RC-S

M3.a.(1)

RC-S

M3.a.(2)

RC-S

M3.b.(1)

RCFDB935,
RCFDB936
RCFDB937,
RCFDB938
RCFDB939,
RCFDB940
RCFDB941,
RCFDB942
RCFDB943,
RCFDB944

MDRM Number
TBD (3 MDRM
Numbers)

RCFDB783,
RCFDB786,
RCFDB787,
RCFDB788,
RCFDB789
Asset-backed commercial paper conduits: RCFDB806
Maximum amount of credit exposure
arising from credit enhancements
provided to conduit structures in the form
of standby letters of credit, subordinated
securities, and other enhancements:
Conduits sponsored by the bank, a bank
affiliate, or the bank’s holding company
Asset-backed commercial paper conduits: RCFDB807
Maximum amount of credit exposure
arising from credit enhancements
provided to conduit structures in the form
of standby letters of credit, subordinated
securities, and other enhancements:
Conduits sponsored by other unrelated
institutions
Asset-backed commercial paper conduits: RCFDB808
Unused commitments to provide liquidity
to conduit structures: Conduits sponsored

78

RC-S

M3.b.(2)

RC-S

M4

by the bank, a bank affiliate, or the
bank’s holding company
Asset-backed commercial paper conduits: RCFDB809
Unused commitments to provide liquidity
to conduit structures: Conduits sponsored
by other unrelated institutions
Outstanding credit card fees and finance
RCFDC407
charges included in Schedule RC-S, item
1, column C

To be completed by banks with $100 billion or more in total assets
Schedule Item
Item Name
RC-S
3
Reporting bank’s unused commitments
to provide liquidity to structures reported
in item 1 (Columns A through G)

79

MDRM Number
RCFDB726,
RCFDB727,
RCFDB728,
RCFDB729,
RCFDB730,
RCFDB731,
RCFDB732